Lazaro v. CA

Facts:

Private respondents sued petitioners for annulment of title, reconveyance and damages in the RTC Bayombong, Nueva Vizcaya. Copy of the decision in favor of petitioners was received by private respondents on December 16, 1997. A notice of appeal was filed on December 19, 1997 but the docket fees were paid six months thereafter. The appellate court dismissed the appeal for failure of respondents to pay the docket fees within the prescribed period. Private respondents moved for its reconsideration citing "interest of substantial justice" but failed to show fraud, accident, mistake, excusable negligence or any other reason to justify suspension of the rule. The appellate court granted the motion without citing any specific circumstance or any other explanation in support of its ruling. Hence, this petition.

Issue: 
Whether or not the appellate court acted without or in excess of jurisdiction, and/or with grave abuse of discretion in issuing the resolutions.

Held:

Yes.

The rule on the payment of the docket and other legal fees is both mandatory and jurisdictional. Failure to pay the same within the prescribed period is a ground for the dismissal of an appeal. The rule cannot be suspended by mere invocation of "interest of substantial justice."

Procedural rules are not to be belittled or dismissed simply because their non-observance may have resulted in prejudice to a party's substantive rights. Like all rules, they are required to be followed except only for the most persuasive of reasons when they may be relaxed to relieve a litigant of an injustice not commensurate with the degree of his thoughtlessness in not complying with the procedure prescribed." The Court reiterates that rules of procedure, especially those prescribing the time within which certain acts must be done, "have oft been held as absolutely indispensable to the prevention of needless delays and to the orderly and speedy discharge of business. . ." Indeed, in no uncertain terms, the Court held that the said rules may be relaxed only in "exceptionally meritorious cases."