G.R. No. 174219; November 23, 2007
KLT FRUITS, INC., JOSEPH LAO TIAK BEN, MICHAEL LAO TIAN BEN, ARLENE LAO and ROGELIO BUAN, Petitioners, vs. WSR FRUITS, INC. and REGIONAL TRIAL COURT OF MANILA, BRANCH 20, Respondents.

FACTS

Private respondent WSR Fruits, Inc. filed a Complaint for Sum of Money with a prayer for a Writ of Preliminary Attachment against petitioners KLT Fruits, Inc. and its officers. WSR alleged that it had a long-standing business relationship with KLT, supplying fruits and later engaging in a check rediscounting arrangement to assist KLT with cash flow problems. Under this arrangement, KLT issued postdated checks to WSR in exchange for cash. In 1998, several checks issued by KLT, totaling ₱3,685,766.00, were dishonored upon presentment for the reason “Account Closed/Stop Payment.” Despite demands, KLT failed to pay, prompting the lawsuit.
The Regional Trial Court (RTC) ruled in favor of WSR, ordering KLT and certain officers to pay the amounts. Petitioners filed a Motion for Reconsideration, which was denied. They then filed a Notice of Appeal with the RTC but failed to pay the corresponding docket fees. WSR moved to dismiss the appeal due to this non-payment and alleged deficiencies in the notice. The RTC granted the motion and dismissed the appeal. The Court of Appeals affirmed this dismissal, prompting the petition to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s dismissal of the appeal for failure to pay the required docket fees.

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the dismissal of the appeal. Payment of the prescribed docket fee is a mandatory and jurisdictional requirement for perfecting an appeal. The rules are explicit: an appeal is deemed perfected only upon the timely filing of the notice of appeal and the payment of the requisite fees. The court acquires jurisdiction over the appeal only upon full compliance with these requirements.
In this case, the petitioners filed their Notice of Appeal but admittedly did not pay the docket fees. This failure is fatal to their appeal. The Court rejected the petitioners’ argument that the dismissal was too harsh, emphasizing that procedural rules must be faithfully complied with. The right to appeal is not a natural right but a statutory privilege that must be exercised in accordance with the law. The petitioners’ non-payment of fees was not a mere technicality but a clear violation of a mandatory rule that deprived the RTC of jurisdiction to entertain the appeal. Consequently, the dismissal of the appeal by the RTC and its affirmation by the Court of Appeals were proper.