G.R. No. 205492 March 11, 2015
REPUBLIC OF THE PHILIPPINES, Petitioner, vs. SPOUSES DANTE and LOLITA BENIGNO, Respondents.

FACTS

On November 2, 1995, respondents Spouses Dante and Lolita Benigno filed an Application for Registration of title under Presidential Decree No. 1529 over a 293-square meter lot in Los Baños, Laguna, docketed as LRC Case No. 105-95-C. The Regional Trial Court (RTC) of Calamba, Laguna, Branch 35, granted the application in a Decision dated December 9, 2005. Petitioner Republic of the Philippines filed a notice of appeal on January 10, 2006, which the RTC approved, directing the transmittal of records to the Court of Appeals (CA), where the appeal was docketed as CA-G.R. CV No. 97995.
The transmittal of records was delayed. Respondents filed a Motion to Dismiss the Appeal on March 9, 2010, claiming petitioner abandoned its appeal. The RTC denied the motion on July 2, 2010, attributing the delay to respondents’ failure to submit required documents (Affidavit of Publication and Certificate of Posting). Respondents filed a Motion for Reconsideration. Without awaiting its resolution, respondents filed a Compliance on September 21, 2011, submitting the required documents. The RTC then directed the transmittal of records to the CA on September 26, 2011. The CA received the records on December 21, 2011.
On February 21, 2012, respondents filed a Motion for Early Resolution, seeking dismissal for petitioner’s alleged failure to prosecute. On May 8, 2012, respondents filed a Manifestation and Motion to Suspend Proceedings, arguing that the filing of an appellant’s brief was premature pending resolution of their motions. The CA, on April 26, 2012, directed petitioner to file its appellant’s brief within 45 days. Petitioner filed a Motion for Extension on June 22, 2012, seeking 60 days, which the CA granted in a June 26, 2012 Resolution. Petitioner filed an Opposition to respondents’ motion to suspend on July 16, 2012.
Petitioner filed a second Motion for Extension on August 17, 2012, seeking an additional 30 days until September 19, 2012, to file its brief. Petitioner failed to file the brief by September 19, 2012. On October 9, 2012, the CA issued a Resolution denying the second motion for extension and dismissing the appeal pursuant to Section 1(e), Rule 50 of the 1997 Rules of Civil Procedure for failure to file the appellant’s brief on time. The CA deemed respondents’ motion to suspend proceedings moot.
On October 18, 2012, petitioner filed a third Motion for Extension. On November 5, 2012, petitioner filed its Appellant’s Brief and an Omnibus Motion seeking reconsideration of the October 9, 2012 Resolution and admission of the brief, arguing the delay was caused by the trial court and respondents, and pleading for leniency in the interest of substantial justice. Respondents opposed, arguing petitioner lacked diligence. On January 22, 2013, the CA denied the Omnibus Motion. Petitioner elevated the case via Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals gravely erred in dismissing the appeal for failure to file the appellant’s brief on time, despite the alleged delay being caused by the trial court and the respondents.

RULING

The Supreme Court granted the Petition, reversed the assailed Resolutions of the Court of Appeals, and remanded the case for further proceedings. The Court held that the dismissal of the appeal was too severe a penalty under the circumstances. While the right to appeal is statutory and requires compliance with rules, procedural rules may be relaxed for persuasive reasons to promote substantial justice. The Court found that the delay in the proceedings was not solely attributable to petitioner. The transmittal of records from the RTC to the CA was significantly delayed due to respondents’ initial failure to submit required documents and the trial court’s processes. Petitioner’s motions for extension were filed on time and for valid reasons, including awaiting the resolution of respondents’ pending motions that sought to suspend the proceedings. Petitioner eventually filed its Appellant’s Brief and demonstrated a willingness to prosecute the appeal. The State, as petitioner, is afforded some leniency in procedural matters to ensure it can fully present its case on the merits, especially in land registration cases where it has the responsibility to protect public domain. The Court emphasized that dismissal of appeals is discretionary and should be used judiciously. The better course was to allow the appeal to proceed and be resolved on its merits, rather than imposing the harsh penalty of dismissal for a procedural lapse under these specific facts.