G.R. No. 159253. July 9, 2007. ISIDRO ANADON and ROMULO ANADON, Petitioners, vs. MIGUELINA HERRERA and JUANITO PANTINOPLE, Respondents.
FACTS

Petitioners Isidro and Romulo Anadon received a copy of the Regional Trial Court (RTC) Decision dismissing their complaint on April 19, 2002. The copy, however, had unreadable pages 1 to 5, with only the dispositive portion being legible. Instead of filing a Notice of Appeal, petitioners filed a Manifestation/Motion on April 29, 2002, requesting a clear copy and arguing that valid service had not been effected. The RTC granted the request on May 10, 2002, and petitioners received the certified copy on May 20, 2002. They subsequently filed their Notice of Appeal on May 24, 2002.
Respondents moved to dismiss the appeal before the Court of Appeals (CA) for being filed out of time. The CA granted the motion, ruling that the reglementary 15-day period to appeal commenced from the April 19, 2002 receipt of the decision, notwithstanding the illegible pages. The CA emphasized that petitioners, knowing their complaint was dismissed from the legible dispositive portion, should have promptly filed a Notice of Appeal and that their 10-day delay in requesting a clear copy demonstrated a lack of due diligence.

ISSUE

Whether the Court of Appeals erred in dismissing the petitioners’ appeal for having been filed out of time.

RULING

Yes, the Supreme Court granted the petition and reinstated the appeal. The Court held that while the right to appeal is statutory and requires compliance with procedural rules, technicalities should not be strictly enforced if they defeat substantial justice and no prejudice is caused to the adverse party. The Court found that the petitioners’ receipt of an unreadable decision copy constituted a valid justification for not immediately filing an appeal.
The legal logic is that the filing of the Manifestation/Motion on April 29, 2002, which was a seasonable plea for a proper copy of the decision, effectively interrupted the running of the appeal period. Only ten days had lapsed from the initial receipt on April 19. Upon receiving the clear copy on May 20, petitioners had a fresh five-day period to appeal, making their Notice of Appeal filed on May 24 timely. The RTC’s act of furnishing a clear copy and giving due course to the appeal was correct. The Supreme Court emphasized that equity jurisdiction allows for flexibility where non-compliance is not intended for delay, and here, respondents would suffer no prejudice from reinstating the appeal. The CA’s dismissal on a technicality was reversed to serve the ends of substantial justice.