GR 72763; (May, 1991) (Digest)
G.R. No. 72763 ; May 29, 1991
ALTO SALES CORPORATION, petitioner, vs. HON. INTERMEDIATE APPELLATE COURT AND PHILIPPINE VIRGINIA TOBACCO ADMINISTRATION, respondents.
FACTS
Petitioner Alto Sales Corporation entered into a Purchase Agreement with respondent Philippine Virginia Tobacco Administration (PVTA) for the sale of tobacco for export. The contract required Alto to apply for an export license from the Central Bank within a reasonable time after the agreement’s approval, failing which the contract would become inoperative. Alto’s president, Antonio Quirino, hand-carried a letter to the Central Bank’s Export Department but did not submit the required Report of Foreign Sales form. PVTA subsequently canceled the contract, alleging Alto’s failure to properly apply for the license. Alto sued for specific performance.
The trial court (Judge Andres Reyes) initially ruled in favor of Alto on May 3, 1968. PVTA filed a motion for reconsideration. Judge Guardson Lood, who inherited the case, later set aside the Reyes decision, dismissed Alto’s complaint, and granted a new trial. The Intermediate Appellate Court initially reversed Lood’s decision and reinstated the Reyes decision but, upon PVTA’s motion for reconsideration, ultimately affirmed Lood’s dismissal.
ISSUE
Whether the Intermediate Appellate Court erred in affirming the trial court’s dismissal by disregarding the final and executory status of the original Reyes decision.
RULING
The Supreme Court ruled in favor of Alto, setting aside the appellate court’s resolutions and reinstating the Reyes decision. The core legal logic rests on the doctrine of finality of judgments. The Court found that the Reyes decision of May 3, 1968, had become final and executory due to PVTA’s failure to perfect its appeal within the reglementary period. Perfection of an appeal within the time fixed by law is mandatory and jurisdictional. The records showed PVTA did not file the requisite notice of appeal, appeal bond, and record on appeal within thirty days from notice of the order denying its motion for reconsideration. Consequently, the trial court lost jurisdiction to alter the judgment, rendering Judge Lood’s subsequent orders setting aside the final decision and granting a new trial null and void. The Supreme Court emphasized that with the finality of the Reyes decision, there was no legal basis for the appellate court to delve into the merits of the contract cancellation. The ruling underscores that adherence to procedural rules on appeal is indispensable for the orderly administration of justice, and a judgment that has attained finality becomes immutable and unalterable.