Decision on small claims unappealable

Persida Acosta

Persida Acosta

Dear PAO,
Can a defendant in a small claims action appeal the decision of the court?

Dear Pete,
Small claims action refers to a Civil Action, the purpose of which is to recover or to enforce the payment of sum of money. It could also be a separate civil action for damages arising from the commission of a crime or the enforcement of a settlement in the barangay involving money claims. This is according to the Rule of Procedure for Small Claims Action (A.M. No. 08-8-7-SC), which provides:

“SEC. 4. Applicability.—The Metropolitan Trial Courts, Municipal Trial Courts in Cities, Municipal Trial Courts, and Municipal Circuit Trial Courts shall apply this Rule in all actions which are: (a) purely civil in nature where the claim or relief prayed for by the plaintiff is solely for payment or reimbursement of sum of money, and (b) the civil aspect of criminal actions, either filed before the institution of the criminal action, or reserved upon the filing of the criminal action in court, pursuant to Rule 111 of the Revised Rules of Criminal Procedure.

These claims or demands may be:

(a) For money owed under any of the following:

1. Contract of Lease;
2. Contract of Loan;
3. Contract of Services;
4. Contract of Sale; or
5. Contract of Mortgage;

(b) For damages arising from any of the following:
1. Fault or negligence;
2. Quasi-contract; or
3. Contract;

(c) The enforcement of a barangay amicable settlement or an arbitration award involving a money claim covered by this Rule pursuant to Sec. 417 of Republic Act 7160, otherwise known as the Local Government Code of 1991.”

In all cases, the amount involved or the value of the claim must not exceed P100,000. (Section 2, A.M. No. 08-8-7-SC)

Small claims action is an abbreviated trial of a case wherein no lawyer is required to represent both parties thereto and it will only take one hearing day for the court to hear the case. Likewise, the decision of the court is final and executory. Therefore, no appeal may be undertaken by the aggrieved party. This is according to Section 23 of the said rule, to wit:

“SEC. 23. Decision.—After the hearing, the court shall render its decision on the same day, based on the facts established by the evidence (Form 13-SCC). The decision shall immediately be entered by the Clerk of Court in the court docket for civil cases and a copy thereof forthwith served on the parties.

The decision shall be final and unappealable.”

Again, we find it necessary to mention that this opinion is solely based on the facts you have narrated and our appreciation of the same. The opinion may vary when the facts are changed or elaborated.

We hope that we were able to enlighten you on the matter.

Editor’s note: Dear PAO is a daily column of the Public Attorney’s Office. Questions for Chief Acosta may be sent to


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