G.R. No. L-54886 September 10, 1981
Republic of the Philippines, petitioner, vs. The Honorable Court of Appeals, Court of First Instance of Bulacan, Turandot, Traviata, Marcelita, Marlene, Pacita, Matthew, Victoria and Rosary, all surnamed Aldaba, respondents.

FACTS

The Republic initiated expropriation proceedings for a 15,000-square-meter lot in Bulacan for a public highway equipment shop. The lower court issued a writ of possession and, upon motion of the landowners, created a three-man committee to determine just compensation, which recommended P50.00 per square meter. The court later approved a modified compensation of P30.00 per square meter in an order dated December 8, 1978. The Solicitor General received a copy of this order on December 18, 1978, and filed a notice of appeal on December 22, 1978. The petitioner subsequently filed multiple motions for extension to submit the record on appeal. The lower court granted four extensions. A fifth motion for extension, dated May 17, 1979, was filed, and the record on appeal itself was submitted on June 7, 1979. The lower court, however, dismissed the appeal, finding that the fifth motion was mailed on May 21, 1979, which was beyond the last day of the previously granted period (April 19 to May 18, 1979), rendering the subsequent record on appeal filed out of time. The Court of Appeals sustained this dismissal.

ISSUE

Whether the Court of Appeals erred in sustaining the dismissal of the petitioner’s appeal for having been perfected out of time.

RULING

The Supreme Court granted the petition, annulling the decisions of the lower courts. The legal logic centered on the substantive rights involved and the proper computation of the appeal period. The Court clarified that the reglementary period to appeal commenced from the petitioner’s receipt of the lower court’s December 8, 1978, order on December 18, 1978. The notice of appeal was filed on December 22, 1978, well within the 30-day period. Critically, the subsequent motions for extension to file the record on appeal were filed before the expiration of the periods sought to be extended. The Court found that the fifth motion, although mailed on May 21, was dated and filed within the extended period ending May 18. The lower court’s focus on the mailing date for dismissal was overly technical. More importantly, the Court emphasized the paramount public interest and the substantial amount of public funds involved—the government stood to lose over P425,000 if the appeal on the allegedly excessive compensation was not heard. Dismissing the appeal on a procedural technicality would prejudice substantial justice, especially where the petitioner raised a meritorious issue regarding the proper application of Presidential Decree No. 76 in determining just compensation. Thus, the appeal was reinstated.