G.R. No. 218867, February 17, 2016
SPOUSES EDMOND LEE and HELEN HUANG, Petitioners, vs. LAND BANK OF THE PHILIPPINES, Respondent.

FACTS

Petitioners-spouses Edmond Lee and Helen Huang are the registered owners of a 5.4928-hectare property in Bataan, a portion of which (1.5073 hectares) was compulsorily acquired by the DAR under the Comprehensive Agrarian Reform Law. Rejecting the DAR’s offered compensation of ₱109,429.98, petitioners filed a petition for determination of just compensation before the Regional Trial Court (RTC) of Balanga City, sitting as a Special Agrarian Court. The RTC, in a Decision dated January 17, 2002, set just compensation at ₱250.00 per square meter, or a total of ₱3,768,250.00. Respondent Land Bank’s motion for reconsideration was denied on June 14, 2002. Respondent filed a Notice of Appeal on June 19, 2002. In 2006, petitioners moved for execution, alleging no appeal was filed. The RTC, in an Order dated June 7, 2007, found the appeal perfected and directed transmittal of records to the Court of Appeals (CA). This was reiterated in an Order dated August 27, 2008, which noted a postal money order was issued for the appeal fee. On April 26, 2013, petitioners moved to dismiss the appeal for failure to prosecute, arguing respondent had taken no action since 2008 and failed to pay the appellate docket fees. The RTC, in an Order dated July 5, 2013, granted the motion, finding that while a postal money order was issued, the amount was never remitted or received by the Clerk of Court, and thus the appeal fees were not paid. The RTC held that without payment, the appeal was not perfected, and it retained jurisdiction to dismiss the appeal for failure to prosecute. Respondent’s motion for reconsideration was denied. The CA, in a Decision dated January 28, 2015, reversed the RTC, finding grave abuse of discretion. The CA held that the RTC’s earlier 2007 and 2008 Orders had already passed upon the validity of the appeal and given it due course; thus, upon perfection of the appeal, the RTC lost jurisdiction, and its subsequent 2013 Order was void. The CA denied petitioners’ motion for reconsideration.

ISSUE

Whether or not the Court of Appeals erred in finding grave abuse of discretion on the part of the Regional Trial Court when it dismissed respondent’s appeal for failure to prosecute.

RULING

The Supreme Court granted the petition, reversing the CA and reinstating the RTC’s Order dismissing the appeal. The Court held that the payment of the full amount of appellate docket and other lawful fees within the prescribed period is both mandatory and jurisdictional for the perfection of an appeal. Citing Section 4, Rule 41 of the Rules of Court and jurisprudence, the Court ruled that without such payment, the appeal is not perfected, the appellate court does not acquire jurisdiction, and the decision becomes final and executory. The Court gave credence to the finding of the RTC’s Officer-in-Charge Clerk of Court that the amount of the postal money order issued by respondent was never remitted or received by the court, constituting a failure to pay the required fees. Consequently, respondent’s appeal was not perfected, and the RTC did not lose jurisdiction over the case. The RTC, therefore, acted within its discretion in dismissing the appeal for failure to prosecute, especially given respondent’s inaction for nearly five years after its Notice of Appeal was given due course. The CA erred in ruling that the RTC lost jurisdiction and committed grave abuse of discretion.