G.R. No. L-50633 August 17, 1981
Calasiao Farmers Cooperative Marketing Association, Inc., and Jose F. Dizon, petitioners, vs. The Honorable Court of Appeals, Honorable Carolina C. Griño-Aquino of the Court of First Instance of Rizal and Aurora Lucero Vda. De Sevilla, respondents.

FACTS

Private respondent Aurora Sevilla was allowed to present evidence ex-parte after petitioners’ counsel failed to appear at a hearing. Petitioners later moved for reconsideration, and the trial court modified its order, setting the case to receive petitioners’ evidence but deeming their cross-examination of Sevilla’s witnesses waived. Judgment was rendered against petitioners on August 31, 1976. Upon receiving the judgment, petitioners filed a motion for reconsideration, which was denied. They then filed a notice of appeal, bond, and a motion for extension to file their Record on Appeal, which the court granted. They subsequently filed a second motion for extension and submitted their original Record on Appeal on December 6, 1976. Respondent Sevilla opposed its approval, arguing it omitted material orders.
The trial court, on January 10, 1977, ordered petitioners to amend their Record on Appeal to include the specified pleadings and orders. The court later granted a further extension to file this amended record. Petitioners filed the Amended Record on Appeal on February 16, 1977. However, on December 19, 1977, the trial court disapproved it for being filed one day late. The Court of Appeals upheld the trial court’s orders, prompting this appeal.

ISSUE

The primary issue is whether the trial court committed grave abuse of discretion in: (1) ordering the amendment of the Record on Appeal to include certain pleadings and orders, and (2) disapproving the Amended Record on Appeal for being filed one day late.

RULING

The Supreme Court affirmed the order to amend the Record on Appeal but set aside the order disapproving the amended record. On the first issue, the Court found no abuse of discretion. Under the Rules of Court, the trial judge is vested with authority to determine what matters are essential for the proper understanding of the issues on appeal. The omitted orders and pleadings, particularly those relating to the ex-parte reception of evidence and the waiver of cross-examination, were deemed necessary as they could form the basis for assignments of error on appeal.
On the second issue, the Court ruled that the trial court did commit an error in disapproving the Amended Record on Appeal. The original Record on Appeal was filed on December 6, 1976, which was within the requested extension period. An amendment to a pleading relates back to the date of the original filing. Therefore, the Amended Record on Appeal, although physically filed later, is deemed to have been presented upon the timely submission of the original. The Court emphasized the policy of deciding appeals on their merits rather than on technicalities. Rules of procedure should not be applied rigidly to defeat substantial justice. Consequently, the trial court was ordered to give due course to the petitioners’ appeal.