G.R. No. L-33095 April 19, 1972
MERCEDES T. SONORA, et al., petitioners, vs. FRANCISCO A. TONGOY, et al., respondents.

FACTS

Petitioners, the Sonoras, filed a complaint for reconveyance of shares in Hacienda Pulo and Cuaycong Property against private respondents, the heirs of Luis D. Tongoy. The Sonoras claimed an implied trust over the lands registered in the estate of Luis D. Tongoy. The trial court dismissed the Sonoras’ complaint but ordered reconveyance to other Tongoy plaintiffs. Both the Sonoras and the private respondents appealed. The Sonoras filed a notice of appeal specifying the Supreme Court as the appellate court, but the trial court’s order directed the records to the Court of Appeals. The Sonoras subsequently participated in the appellate proceedings before the Court of Appeals.
The Court of Appeals, upon motion of private respondents, dismissed the Sonoras’ appeal. It held that since the notice of appeal specified the Supreme Court, the Court of Appeals could not entertain it, and as no petition for review was filed with the Supreme Court, the appeal was not perfected. The Supreme Court initially treated the Sonoras’ petition as an appeal but later considered it as an original action for certiorari due to the manifest error in the appellate court’s resolution.

ISSUE

Whether the Court of Appeals erred in dismissing the Sonoras’ appeal outright instead of certifying it to the proper court, considering the specification in their notice of appeal that it was directed to the Supreme Court.

RULING

Yes, the Court of Appeals committed a grave error. The Supreme Court granted the petition and directed the Court of Appeals to give due course to the Sonoras’ appeal. The legal logic is clear: jurisdictional provisions for erroneously filed appeals are designed to prevent the loss of appellate rights due to technical mistakes. Section 31 of the Judiciary Act mandates that cases erroneously brought to the Supreme Court or Court of Appeals shall be sent to the proper court. Rule 50, Section 3 of the Rules of Court explicitly states that the Court of Appeals shall not dismiss an erroneously brought case but shall certify it to the proper court.
The specification of the appellate court in a notice of appeal is merely directory, not jurisdictional. The ruling in Valerio v. Tan established that failure to comply or an error in indicating the court is not fatal. Furthermore, practical considerations of judicial economy and consistency necessitate that the Sonoras’ appeal be heard by the Court of Appeals alongside the private respondents’ appeal. In Roman Santos v. Francisco Baylon, the Supreme Court held that when appeals from the same decision involve interrelated factual and legal issues, they should be consolidated in the Court of Appeals, the tribunal vested with fact-review authority, to avoid conflicting decisions. Here, the private respondents’ appeal challenges the trial court’s factual findings, which could directly impact the legal questions the Sonoras raise. Therefore, both appeals are inextricably linked and must be resolved jointly by the Court of Appeals.