G.R. No. L-63737. June 27, 1985. PEDRO BISNAR and PETRONILA BISNAR, Petitioners, vs. HON. JUDGE JOSE G. ESTRADA, in his capacity as Regional Trial Court Judge, Branch VI, Mati, Davao Oriental, and TIMIDINO INTING, Respondents.
FACTS

Private respondent Timidino Inting filed a complaint for accounting and damages against petitioners Pedro and Petronila Bisnar on September 8, 1977, docketed as Civil Case No. 613. After trial, the Court of First Instance rendered a decision in favor of Inting on December 29, 1982. The petitioners received a copy of this adverse decision through their original counsel on January 5, 1983. Their original counsel subsequently withdrew, and their new counsel, Antonio K. Cañon, filed a notice of appeal on February 4, 1983.
The respondent Regional Trial Court Judge dismissed the appeal on February 8, 1983, and later denied a motion for reconsideration on March 11, 1983. The dismissal was based solely on the ground that the appeal was filed out of time. The judge applied Batas Pambansa Blg. 129, which took effect on January 17, 1983, prescribing a 15-day appeal period. The court computed that from the effectivity date, the appeal period expired on February 1, 1983, making the February 4 filing three days late.

ISSUE

Whether the respondent judge committed a grave abuse of discretion in dismissing the petitioners’ appeal as belated by applying the new 15-day appeal period under Batas Pambansa Blg. 129 retroactively to a case where the right to appeal had already vested under the old law.

RULING

Yes, the Supreme Court ruled that the respondent judge committed grave abuse of discretion. The legal logic centers on the non-retroactive application of procedural laws when such application would impair vested rights. When the petitioners received the decision on January 5, 1983, the governing law granted a 30-day period to appeal, or until February 4, 1983. The subsequent effectivity of Batas Pambansa Blg. 129 on January 17, 1983, which shortened the appeal period to 15 days, could not be applied to cut short a right that had already accrued. To hold otherwise would be a retroactive application prejudicial to the petitioners, who were still within their original 30-day window when the new law took effect.
The Court emphasized the principle that remedial laws should be construed liberally to afford litigants ample opportunity to prove their claims and to avoid the denial of substantial justice due to technicalities. Since the notice of appeal was filed on February 4, 1983, which was within the original 30-day period ending that same day, the appeal was timely perfected. The orders of dismissal were therefore set aside, and the respondent judge was ordered to give due course to the appeal and forward the records to the Intermediate Appellate Court.