The Supreme Court held that failure to comply strictly with the rules regarding the period for filing a petition for review with the Court of Appeals (CA) is a jurisdictional defect that warrants the denial of the appeal. The Court emphasized that the right to appeal is statutory and must be exercised in accordance with established procedures. This ruling underscores the importance of adhering to deadlines and procedural requirements in appellate practice, as failure to do so can result in the loss of the right to appeal, regardless of the merits of the case.

When a Motion for Extension of Time Leads to Dismissal: A Case of Missed Deadlines

This case revolves around Wilson T. Go’s appeal of a decision ordering him to pay BPI Finance Corporation (BPI) a sum of money for unpaid credit card charges. The Metropolitan Trial Court (MeTC) initially ruled against Go, a decision affirmed by the Regional Trial Court (RTC). Dissatisfied, Go sought to appeal to the Court of Appeals (CA). However, his petition for review was denied because it was filed beyond the extended period granted by the CA. The central legal question is whether Go’s failure to file the petition within the prescribed time frame is a fatal procedural lapse that justifies the dismissal of his appeal.

The timeline of events is crucial. After the RTC denied his motion for reconsideration, Go had fifteen days to file a petition for review with the CA. He then filed a motion for extension of time, requesting thirty days. However, the CA only granted a fifteen-day extension. Go, mistakenly believing he had thirty days, filed his petition after the fifteen-day extension had lapsed. The CA denied his petition, stating it was filed out of time. Go argued that he was only informed of the 15-day extension after his motion and petition was filed and that he was denied due process.

The Supreme Court (SC) upheld the CA’s decision, emphasizing the mandatory nature of the rules on appeal. The SC cited Section 1, Rule 42 of the Rules of Court, which governs appeals from the RTC to the CA.

Section 1. How appeal taken; time for filing. — A party desiring to appeal from a decision of the Regional Trial Court rendered in the exercise of its appellate jurisdiction may file a verified petition for review with the Court of Appeals, paying at the same time to the clerk of said court the corresponding docket and other lawful fees, depositing the amount of P500.00 for costs, and furnishing the Regional Trial Court and the adverse party with a copy of the petition. The petition shall be filed and served within fifteen (15) days from notice of the decision sought to be reviewed or of the denial of petitioner’s motion for new trial or reconsidera­tion filed in due time after judgment. Upon proper motion and the payment of the full amount of the docket and other lawful fees and the deposit for costs before the expiration of the reglementary period, the Court of Appeals may grant an additional period of fifteen (15) days only within which to file the petition for review. No further extension shall be granted except for the most compelling reason and in no case to exceed fifteen (15) days.

The Court emphasized that the right to appeal is statutory, not a natural or constitutional right. As such, compliance with the prescribed procedures is mandatory. The SC also noted that Go could not simply assume his motion for a 30-day extension would be granted. It is the responsibility of the appealing party to diligently monitor the status of their motion and to comply with the rules even if the court takes time to resolve the motion.

The Supreme Court also addressed Go’s claim of denial of due process. The Court stated that the denial of the appeal was not based on a mere technicality but on a jurisdictional requirement. Failure to perfect an appeal within the prescribed period renders the judgment final and executory. This principle ensures the stability and finality of judicial decisions, preventing endless litigation.

The SC also cited the case of Lacsamana v. IAC, which set the policy of granting only a fifteen-day extension for filing a petition for review. The Court reiterated that an appellant cannot assume that a requested 30-day extension will be granted. It is up to the court to determine whether to grant the motion and for what duration. Furthermore, the SC emphasized that its review is generally limited to questions of law, and it is bound by the factual findings of the lower courts unless there is grave abuse of discretion. Thus, even on the merits, the Court found no reason to overturn the lower courts’ decisions.

This case underscores the importance of diligence and adherence to procedural rules in appellate practice. Litigants and their counsels must be aware of the strict deadlines for filing appeals and must not assume that motions for extension will be granted as requested. The failure to comply with these rules can result in the loss of the right to appeal, regardless of the perceived merits of the case. This ruling serves as a cautionary tale for those seeking to challenge lower court decisions, emphasizing the need for meticulous attention to procedural requirements. Ultimately, the stability and finality of judicial decisions depend on the consistent application of these rules.

FAQs

What was the key issue in this case?	The key issue was whether the petitioner’s failure to file his petition for review within the extended period granted by the Court of Appeals warranted the denial of his appeal.
What is the reglementary period for filing a petition for review with the CA?	The reglementary period is fifteen (15) days from notice of the decision sought to be reviewed or of the denial of a motion for new trial or reconsideration.
Can the CA grant an extension of time to file a petition for review?	Yes, the CA may grant an additional period of fifteen (15) days only within which to file the petition for review.
What happens if a party fails to file the petition within the extended period?	Failure to file the petition within the extended period renders the appeal dismissible for being filed out of time, as it is a jurisdictional defect.
Is the right to appeal a constitutional right?	No, the right to appeal is a statutory right, not a natural or constitutional right, and must be exercised in accordance with the prescribed procedures.
What was the petitioner’s argument in this case?	The petitioner argued that he was only informed of the 15-day extension four months after he filed his motion, and that he was denied due process.
How did the Supreme Court rule on the petitioner’s argument?	The Supreme Court rejected the petitioner’s argument, stating that he could not assume his motion for a 30-day extension would be granted and that failure to perfect an appeal within the prescribed period is a jurisdictional defect.
What is the significance of the Lacsamana v. IAC case in this ruling?	Lacsamana v. IAC established the policy of granting only a fifteen-day extension for filing a petition for review, which the Supreme Court cited to emphasize the strict application of procedural rules.

This case serves as a reminder of the importance of adhering to procedural rules in appellate practice. Failure to comply with these rules can have significant consequences, including the loss of the right to appeal. Parties must ensure they understand and comply with all applicable deadlines and procedures to protect their legal rights.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Wilson T. Go v. BPI Finance Corporation, G.R. No. 199354, June 26, 2013