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Sps Delas Santos Vs v. Vda. de Mangubat

The case Sps. Delos Santos v. Vda. De Mangubat involves a dispute over a right of way through Lot 1034, which the RTC initially granted but denied damages. The Supreme Court ruled that the 'fresh period rule' for filing appeals can be applied retroactively, allowing petitioners to file their Notice of Appeal within the new timeframe. The Court emphasized that procedural rules should facilitate justice and not hinder it, permitting relaxation of strict compliance to ensure fairness.

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MICHAEL ADOLFO
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38 views7 pages

Sps Delas Santos Vs v. Vda. de Mangubat

The case Sps. Delos Santos v. Vda. De Mangubat involves a dispute over a right of way through Lot 1034, which the RTC initially granted but denied damages. The Supreme Court ruled that the 'fresh period rule' for filing appeals can be applied retroactively, allowing petitioners to file their Notice of Appeal within the new timeframe. The Court emphasized that procedural rules should facilitate justice and not hinder it, permitting relaxation of strict compliance to ensure fairness.

Uploaded by

MICHAEL ADOLFO
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PPTX, PDF, TXT or read online on Scribd
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Sps. Delos Santos v. Vda.

De Mangubat, G.R. NO.


149508, October 10, 2007

FACTS
Properties involved: Private respondents owned Lot 1033; petitioners lived on
adjacent Lot 1034 in Sta. Maria, Bulacan

Complaint: Respondents filed for damages and a preliminary injunction on June 5,


1998, claiming a 1991 Deed of Assignment granted them a permanent right of way
through Lot 1034, and alleging petitioners obstructed it with sand and gravel .
• Proceedings:
•
On May 3, 2000, RTC granted the right of way—2.7 m wide × 21 m long
—subject to ₱28,350 indemnity, but denied damages. Petitioner
received the order on May 12, 2000.
•
Petitioners filed a motion for reconsideration on May 29, 2000 (via
registered mail); the RTC denied it on July 19, received by petitioners on
August 3.
• They filed a Notice of Appeal on August 15, 2000, which the RTC denied
on August 17 for being untimely.
• The petitioners then sought certiorari relief from the CA, which
dismissed their petition on October 27, 2000, and again on
reconsideration on July 3, 2001, citing procedural defects: verification
signed by counsel and lack of prior motion for reconsideration.
ISSUE

WON the new 15 day period or fresh


period rule can be applied retroactively
in this case.
RULING
• Yes.
•
It held that the “fresh period rule” is procedural (remedial) and therefore
may apply retroactively to ongoing cases. The petitioners’ Notice filed on
August 15—12 days after receipt of the denial order on August 3—fell within
the 15-day fresh period
•
The Court emphasized that procedural rules are tools to facilitate justice, not
obstacles, and must yield where strict application would produce injustice.
• Rules governing how courts enforce rights (pleadings, motions, time
periods, appeals)—distinct from substantive law which defines the
rights themselves.

• Procedural rules may be applied retroactively to ongoing,


undetermined cases, since they do not create substantive rights
• Following Neypes, parties get a new 15-day period to file an appeal
after a motion for reconsideration is denied. This is procedural and
subject to retroactive application.

• Procedural technicalities (e.g., late filing, improper signature) should


not bar review if doing so would deny substantial justice. Courts can
relax strict compliance in aid of fairness and judicial efficiency.

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