Mere filing of NOTICE suffices if NO record on appeal required

The provisions of Section 2, Rule 40 of the Revised Rules of Court have been modified by Section 20 of the Interim Rules and Guidelines issued by this Court on January 11, 1983 relative to the implementation of the Judiciary Reorganization Act of 1981 (B.P. Blg. 129) and insofar as the requirement for taking an appeal from an inferior court to the regional trial court is concerned. Under said Section 20, the only requirement for taking an appeal from the judgment or order of the metropolitan trial courts, municipal trial courts or municipal circuit courts to the regional trial courts, in cases where no record on appeal is required, is the filing of a notice of appeal. Said appeal is deemed perfected upon the expiration of the last day to appeal by any party.