G.R. No. L-49379 June 29, 1981
TEODORA A. ARITAO, RAYMUNDO ALVAREZ and HILARIO ALVAREZ, petitioners, vs. HON. COURT OF APPEALS, COL. VICTOR M. PUNZALAN, JULIANA PUNZALAN and VICTORIA PUNZALAN, respondents.

FACTS

Private respondents, the Punzalans, filed an action for Forcible Entry against petitioners, the Aritaos, in the Municipal Court of Pangil, Laguna. The Municipal Court decided in favor of the Punzalans, awarding them possession. The Aritaos appealed to the Court of First Instance (CFI), which affirmed the Municipal Court’s judgment in toto. The Aritaos then filed a Notice of Appeal, Appeal Bond, and Record on Appeal to further appeal the CFI’s decision. The Punzalans moved to remand the case for execution, arguing the CFI decision had become final because the Aritaos did not file the proper Petition for Review within the reglementary period. The CFI approved the Aritaos’ Record on Appeal. The Punzalans challenged this via certiorari in the Court of Appeals, which annulled the CFI’s orders, ruling the proper remedy was a Petition for Review, not an ordinary appeal via Record on Appeal.

ISSUE

Whether the Court of Appeals correctly ruled that the proper mode to appeal the decision of the Court of First Instance, which affirmed a Municipal Court judgment in a forcible entry case, is by Petition for Review and not by ordinary appeal via Record on Appeal.

RULING

Yes, the Court of Appeals is correct. The legal logic is grounded on the explicit provision of Section 45 of the Judiciary Act, as amended by Republic Act No. 6031 . This law governs appeals from cases falling under the exclusive original jurisdiction of municipal and city courts. It provides that when such a case is appealed to the CFI, the decision of the CFI shall be final, subject to review only via a Petition for Review based on specific grounds concerning findings of fact and conclusions of law. The Supreme Court, citing its precedent in Gutierrez vs. Magat, categorically held that RA 6031 “does not allow an appeal by record on appeal from the decision of the Court of First Instance in an appealed case falling under the exclusive original jurisdiction of the inferior court.” The evident legislative intent was to abolish ordinary appeals in such cases to ensure a speedy disposition. Since the forcible entry case originated from the Municipal Court’s exclusive jurisdiction, the Aritaos’ filing of a Record on Appeal was procedurally incorrect. The only permissible mode to seek further review of the CFI’s affirmatory decision was through a Petition for Review. However, in the interest of equity and considering a separate action for quieting of title between the parties was pending, the Supreme Court, while affirming the Court of Appeals, gave the petitioners a 15-day period to file the proper Petition for Review.