GR 163022; (February, 2005) (Digest)
G.R. No. 163022 ; February 28, 2005
MEATMASTERS INTERNATIONAL CORPORATION, petitioner, vs. LELIS INTEGRATED DEVELOPMENT CORPORATION, respondent.
FACTS
Petitioner Meatmasters International Corporation filed a complaint for rescission of contract and damages against respondent Lelis Integrated Development Corporation for failing to complete a construction project within the stipulated period. The Regional Trial Court (RTC) rendered a decision rescinding the contract. Respondent received a copy of the decision on December 9, 1998, filed a motion for reconsideration which was denied, and received the denial on March 25, 1999. Respondent then filed a notice of appeal on March 29, 1999, the last day of the appeal period.
The RTC initially dismissed the appeal for non-payment of docket fees but later reconsidered and gave it due course upon respondent’s payment via postal money order dated April 30, 1999—one month after the appeal period lapsed. The Court of Appeals subsequently set aside the RTC decision and ruled in favor of respondent. Petitioner now assails the appellate court’s decision, arguing that the RTC’s judgment had already attained finality due to the late payment of docket fees.
ISSUE
Whether the Court of Appeals erred in entertaining the appeal despite the finality of the trial court’s decision due to the late payment of docket fees.
RULING
The Supreme Court granted the petition and set aside the Court of Appeals’ decision. The Court ruled that the payment of the full docket fee within the prescribed period is a mandatory and jurisdictional requirement for the perfection of an appeal. This is not a mere technicality but an essential condition, and failure to comply renders the trial court’s decision final and executory.
In this case, respondent’s notice of appeal was filed on the last day, March 29, 1999, but the docket fee was paid only on April 30, 1999. Consequently, at the time of payment, the RTC decision had already attained finality. The trial court’s act of giving due course to the appeal effectively extended the appeal period without legal basis. The Court emphasized that while procedural rules may be relaxed under exceptional circumstances—such as fraud, accident, mistake, or excusable negligence—respondent offered no convincing justification, merely citing “oversight.” This flimsy excuse did not warrant the suspension of the rules. Thus, the RTC decision is declared final and executory.