GR 166988; (July, 2009) (Digest)
G.R. No. 166988 ; July 3, 2009
HEIRS OF EMILIANO SAN PEDRO, represented by LUZVIMINDA SAN PEDRO CUNANAN, Petitioners, vs. PABLITO GARCIA and JOSE CALDERON, Respondents.
FACTS
The petitioners, heirs of Emiliano San Pedro, filed a complaint before the DARAB seeking to nullify a sale and a mortgage of a 1.8627-hectare farm lot in Bulacan. They alleged that Emiliano was the rightful beneficiary under Presidential Decree No. 27 (Operation Land Transfer) but had sold a portion to respondent Jose Calderon in 1980 and mortgaged another portion to respondent Pablito Garcia in 1982. Garcia eventually came to control the entire landholding. The petitioners argued these conveyances were void for violating P.D. No. 27 and sought restoration of possession upon payment of the loan.
The Provincial Adjudicator dismissed the complaint, finding Emiliano was not the real tenant and had violated agrarian laws by employing tenants and subsequently abandoning the landholding. The petitioners filed a belated appeal to the DARAB Central Office, which reversed the Adjudicator and ruled in their favor. On appeal, the Court of Appeals reinstated the Adjudicator’s dismissal, holding that the DARAB Central Office had no jurisdiction because the petitioners’ appeal was filed out of time, rendering the Adjudicator’s decision final and executory.
ISSUE
Whether the Court of Appeals erred in ruling that the DARAB Central Office had no jurisdiction to entertain the petitioners’ appeal due to its being filed beyond the reglementary period.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is anchored on the doctrine of finality of judgments and the mandatory nature of procedural rules on appeal periods. The Provincial Adjudicator’s decision was rendered on September 20, 1995. The 1994 DARAB Rules of Procedure provided a 15-day period to appeal. The petitioners filed their Notice of Appeal only on February 5, 1997, which was indisputably over a year late. The Court emphasized that the right to appeal is not a natural right but a statutory privilege that must be exercised in accordance with the law. The failure to perfect an appeal within the prescribed period renders the decision final and executory, depriving the appellate body of jurisdiction to alter it. The DARAB Central Office thus acted without jurisdiction when it entertained the belated appeal. The Court rejected the petitioners’ claim of excusable negligence, finding no compelling reason to relax the procedural rules, as adherence to periods is crucial to the orderly administration of justice. Consequently, the Provincial Adjudicator’s dismissal, having become final, must stand.