G.R. No. L-33186 June 27, 1988
ANUNCIACION DEL CASTILLO, petitioner, vs. MIGUEL DEL CASTILLO and the HON. COURT OF APPEALS, respondents.

FACTS

The case originated from an action for partition and damages filed by Miguel del Castillo and his brothers against their siblings, including Anunciacion del Castillo, concerning a parcel of land in Mandaue. The complaint sought the annulment of a deed of donation executed by Miguel in favor of Anunciacion and a subsequent deed of extra-judicial partition that excluded Miguel. After trial, the Court of First Instance rendered judgment, declaring all parties as co-owners and partitioning the property. Crucially, the trial court upheld the validity of the deed of donation from Miguel to Anunciacion, awarding Anunciacion a specific portion that included the donated share. Only one party, Flaviano del Castillo, appealed this trial court decision to the Court of Appeals.

ISSUE

Whether the Court of Appeals erred in granting affirmative relief to appellee Miguel del Castillo, who did not appeal, by modifying the trial court’s judgment to nullify part of the donation in his favor.

RULING

Yes, the Court of Appeals committed reversible error. The Supreme Court reversed the appellate court’s decision, reinstating the trial court’s judgment regarding the donation. The ruling is anchored on the fundamental procedural rule that an appellee who has not taken an appeal cannot obtain affirmative relief from the appellate court that would modify the judgment to give him more than what was awarded by the trial court. In this case, Miguel del Castillo did not appeal from the trial court’s decision, which had validated the donation and allocated the property accordingly. The only appellant was Flaviano, whose appeal was limited to contesting the reduction of his own share to accommodate Miguel’s award; Flaviano explicitly accepted the validity of the donation to Anunciacion. Despite this, the Court of Appeals, responding to arguments in Miguel’s appellee’s brief, proceeded to declare the donation null and void in part, thereby granting Miguel a larger share (Lot No. 179-F) than the trial court had allotted. This action constituted an impermissible grant of affirmative relief to a non-appealing party. The Supreme Court emphasized that an appellate court’s jurisdiction is generally confined to the issues raised by the appellant and that it cannot award greater relief to an appellee who did not appeal. Consequently, the portion of the Court of Appeals’ decision nullifying the deed of partition concerning Lot No. 179-F and awarding it to Miguel was set aside, and the trial court’s original adjudication in favor of Anunciacion was sustained.