FRESH PERIOD RULE:

   In Neypes v. Court of Appeals, G.R. No. 141524, September 14, 2005, 469 SCRA 633, 644, the Court declared that a party-litigant should be allowed a fresh period of 15 days within which to file a notice of appeal in the RTC, counted from receipt of the order dismissing or denying a motion for new trial or motion for reconsideration, so as to standardize the appeal periods provided in the Rules of Court and do away with the confusion as to when the 15-day appeal period should be counted.  Furthermore, in Sumiran v. Damaso, G.R. No. 162518, August 19, 2009, 596 SCRA 450, 455, the Court again emphasized that the ruling in Neypes, being a matter of procedure, must be given retroactive effect and applied even to actions pending in this Court. (RAMON TORRES and JESSIE BELARMINO vs. SPOUSES VIHINZKY ALAMAG and AIDA A. NGOJU, Respondents, G.R. No. 169569, August 3, 2010, PERALTA, J.).