In Ma. Corazon M. Ola v. People of the Philippines, the Supreme Court addressed the critical distinction between final and interlocutory orders in the context of appellate procedure. The Court ruled that the remedy against an adverse disposition by the Court of Appeals (CA) depends on whether the disposition is a final order or an interlocutory one. If the order is final, a petition for review on certiorari under Rule 45 of the Rules of Court is appropriate. However, if the order is interlocutory, a petition for certiorari under Rule 65 is the correct remedy. This distinction is crucial because using the wrong procedure can lead to the dismissal of an appeal, as it did in this case. This case underscores the importance of understanding procedural rules to ensure that legal rights are properly asserted and protected.

Amending Missteps: When Procedural Lapses Cost a Case

The case originated from an Information filed with the Regional Trial Court (RTC) of Las Piñas City, charging Ma. Corazon Ola, Manuel Hurtada, and Aida Ricarse with estafa under Article 315, paragraph 2 of the Revised Penal Code. The accused allegedly defrauded Elizabeth T. Lauzon by falsely claiming they were authorized to sell a parcel of land, inducing her to pay P420,000.00 as part of the purchase price. After trial, the RTC found Ola and her co-accused guilty of other forms of swindling under Article 316 of the Revised Penal Code and sentenced them to imprisonment and ordered them to jointly and severally indemnify the complainant. Ola and the other accused appealed the RTC Decision to the CA. Ola then filed a motion for leave of court to file an amended appellant’s brief, which the CA denied for being filed out of time. Ola’s subsequent motions for reconsideration and extension of time were also denied, leading her to file a petition for review on certiorari with the Supreme Court, arguing that the CA erred in denying her motion to amend her brief.

The Supreme Court dismissed Ola’s petition due to a procedural infirmity. The Court emphasized that the CA’s denial of the motion to amend the appellant’s brief was an interlocutory order, not a final one. Therefore, the proper remedy was a petition for certiorari under Rule 65, not a petition for review on certiorari under Rule 45. The Court cited Republic of the Phils., v. Sandigahbayan (Fourth Division), et al., where the distinction between final and interlocutory orders was clearly defined:

Case law has conveniently demarcated the line between a final judgment or order and an interlocutory one on the basis of the disposition made. A judgment or order is considered final if the order disposes of the action or proceeding completely, or terminates a particular stage of the same action; in such case, the remedy available to an aggrieved party is appeal. If the order or resolution, however, merely resolves incidental matters and leaves something more to be done to resolve the merits of the case, the order is interlocutory and the aggrieved party’s remedy is a petition for certiorari under Rule 65.

The Court reasoned that because the CA had not yet ruled on the merits of Ola’s appeal, the denial of the motion to amend the brief was merely an incidental matter. The CA still had to determine whether Ola was indeed guilty of estafa. Therefore, the Supreme Court found no reason to deviate from the rule on dismissal of appeals under Section 5, Rule 56 of the Rules of Court. This rule allows for the dismissal of an appeal if there is an error in the choice or mode of appeal.

The Supreme Court also addressed Ola’s argument that the denial of her motion to amend her brief deprived her of due process. The Court clarified that the constitutional provision requiring courts to express the facts and law on which their decisions are based applies only to decisions on the merits, not to interlocutory orders. Furthermore, the Court noted that the CA’s resolution clearly laid out the factual and procedural premises for denying Ola’s motion.

Ola also argued for a liberal interpretation of the Rules of Court, contending that Rule 10 on amendments of pleadings should govern her case, rather than Section 4, paragraph 2, Rule 124. However, the Court found that Ola’s motion for leave to file an amended appellant’s brief was filed seventy-nine (79) days late, making the delay unjustifiable. Even under Rule 10, substantial amendments after a responsive pleading require leave of court, which may be refused if the motion is intended to delay the proceedings.

Moreover, the Court stated that appeals are statutory rights that must be exercised in the manner prescribed by law. The rules governing pleadings and practice before appellate courts are designed to assist the courts in their tasks and enhance the orderly administration of justice. Failure to comply with these rules can result in the denial of the appeal.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals’ denial of a motion to amend an appellant’s brief is a final or interlocutory order, and consequently, whether the correct remedy was a petition for review on certiorari or a petition for certiorari.
What is the difference between a final and interlocutory order?	A final order disposes of the action completely, while an interlocutory order resolves incidental matters and leaves something more to be decided. The remedy against a final order is an appeal, while the remedy against an interlocutory order is a petition for certiorari.
Why was the petitioner’s appeal dismissed?	The petitioner’s appeal was dismissed because she filed a petition for review on certiorari against an interlocutory order, which is the wrong remedy. The correct remedy would have been a petition for certiorari under Rule 65.
What is the significance of Rule 45 and Rule 65 in this case?	Rule 45 governs petitions for review on certiorari, which are appropriate for final orders. Rule 65 governs petitions for certiorari, which are appropriate for interlocutory orders when there is grave abuse of discretion.
Did the Supreme Court address the petitioner’s due process argument?	Yes, the Supreme Court held that the constitutional requirement to express the facts and law applies to decisions on the merits, not interlocutory orders. It also noted that the CA’s resolution clearly stated the reasons for denying the motion.
What was the petitioner’s argument regarding the interpretation of the Rules of Court?	The petitioner argued that the principle of liberal interpretation should apply, and that Rule 10 on amendments of pleadings should govern the case. The Court rejected this argument, citing the petitioner’s unjustified delay.
What is the consequence of filing motions late?	Filing motions late can result in their denial, as it did in this case. The Court noted that the petitioner’s motion was filed seventy-nine days late, making the delay unjustifiable.
Can the rules of procedure be relaxed?	While procedural rules can be relaxed in certain exceptional circumstances, this is not a matter of right. They are designed to assist the appellate court in the accomplishment of its tasks, and overall, to enhance the orderly administration of justice.

In conclusion, the Supreme Court’s decision in Ma. Corazon M. Ola v. People of the Philippines underscores the critical importance of adhering to procedural rules in appellate practice. Failing to distinguish between final and interlocutory orders and choosing the wrong mode of appeal can have dire consequences, leading to the dismissal of a case. This ruling serves as a reminder to legal practitioners and litigants alike to meticulously follow the prescribed procedures to ensure that their legal rights are properly asserted and protected.

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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: MA. CORAZON M. OLA v. PEOPLE, G.R. No. 195547, December 02, 2015