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Siguenza v.

CA for the purpose of enabling the latter to obtain a loan from the
Government Service and Insurance System.
FACTS: Since the loan did not materialize. the whole transaction collapsed and
during the process of reverting the lots back to the subdivision, the
Spouses Quimbo (private respondents) filed a complaint before spouses Quimbo showed interest and deposited money for the lots
the CFI of Cebu against Carmen and Helena Siguenza (petitioners) although they were fully aware of the status of the said lots and after the
together with Bert Osmeña and Associates for breach of contract and down payment no further installments were paid by the spouses.
payment of damages. The trial court rendered judgment in favor of the spouses Quimbo.
On April 14, 1975, the petitioners received a copy of the decision. On
The complaint alleged that the petitioners entered into a contract April 29, 1975, they filed their motion for reconsideration and on May 14,
with the spouses Quimbo for the sale of two lots purportedly owned by 1975, but was denied.
Carmen and Helena Siguenza, and which were Identified as Lot Nos. 1
and 2, Block 1, Phase II of the Clarita Village The petitioners received the copy of the above order on May 27,
1975. On the same day, they filed their notice of appeal, appeal bond,
The said lots were to be paid in the total amount of P15,200.00 and motion for extension of time to file the record on appeal.
of which the amount of P3,040.00 was to be paid upon the execution of
the contract of sale and the balance of P12,160.00 to be paid in monthly On May 29, 1975, the spouses Quimbo filed a motion for
installments and that subsequently, however, the spouses Quimbo execution of judgment against the petitioners on the ground that the
discovered that as early as 1969, the petitioners had already sold and judgment had become final and executory for failure of the petitioners to
conveyed the same lots to Irenea D. Maningo and that both are now perfect their appeal on time.
covered by different Transfer Certificates of Titles in the name of the
latter. On June 30, 1975, the trial court issued the writ of execution
prayed for by the spouses Quimbo on the grounds that the motions filed
The complaint further alleged that because of this double sale, by the petitioners were pro forma as they were based on forgotten
the spouses Quimbo demanded from the petitioners the return of their evidence, i.e., the deed of partition, and that said motions were not
down payment but the latter refused and that as a consequence of the supported by affidavits of merit thus making them fatally defective.
deceit and misrepresentation employed upon them by said petitioners,
the spouses were also prevented from constructing their house worth The trial court likewise disapproved the petitioners' notice of
P100,000.00 on the lots which if constructed at the present would cost appeal, appeal bond, and motion for extension to file a record on appeal
them three hundred (300%) percent more than the original amount. for having become academic.
In their answer, petitioners admitted the sale of the lots to the spouses
but argued that they had nothing to do with the sale as the one On appeal, the Court of Appeals affirmed the trial court's
responsible was Bert Osmeña and Associates. Petitioners also alleged decision. “for the reason that we have here considered as granted the
that the impleading of Carmen Siguenza as a party defendant had no extension of 20 days to petitioner but despite this period, their record on
basis because the lots in dispute were originally registered only in the appeal was filed out of time. Besides, petitioners have no right to
name of Helena Siguenza. presume that their motion would be granted. Neither can respondent
Court be compelled by mandamus to approve the appeal when the same
The other defendant, Bert Osmeña and Associates admitted the was not perfected within the reglementary period.” Hence, this appeal.
sale of the lots to Irenea Maningo but countered that such sale was only
ISSUES: to obtain the same judgment that could very well be laid down through
this petition.
Whether or not the petitioners' appeal was perfected on time.

HELD:

YES. In Castro v. Court of Appeals (132 SCRA 782), the Court


stressed the importance and real purpose of the remedy of appeal and
ruled:
● An appeal is an essential part of our judicial system, We have
advised the courts to proceed with caution so as not to deprive a
party of the right to appeal and instructed that every party-litigant
should be afforded the amplest opportunity for the proper and
just disposition of his cause, freed from the constraints
technicalities.
● The rules of procedure are not to be applied in a very rigid and
technical sense. The rules of procedure are used only to help
secure not override substantial justice. Therefore, we ruled in
Republic v. Court of Appeals (83 SCRA 453) that a six-day delay
in the perfection of the appeal does not warrant its dismissal.
And again in Ramos v.Bagasao (96 SCRA 395), this Court held
that the delay of four (4) days in filing a notice of appeal and a
motion for extension of time to file a record on appeal can be
excused on the basis of equity.
● We should emphasize, however, that we have allowed the filing
of an appeal in some cases where a stringent application of the
rules would have denied it, only when to do so would serve the
demands of substantial justice and in the exercise of our equity
jurisdiction.
In the case at bar, the petitioners' delay in filing their record on
appeal should not be strictly construed as to deprive them of the right to
appeal especially since on its face the appeal appears to be impressed
with merit.

In the interest of justice and the speedy disposition of cases, the


Court have also deemed it proper to decide this case on the merits as a
remand to the lower court for approval of the appeal, its subsequent
elevation to the appellate court and probably, another resort to this Court
would only entail undue burden on the parties and needless delays only