Short answer. Yes, the trial court can. Before transmitting the original record or record on appeal, the trial court may, on its own motion or a party's motion, dismiss the appeal if it was taken out of time or if the docket and other lawful fees weren't paid within the reglementary period.
What the law says
Prior to the transmittal of the original record or the record on appeal to the appellate court, the trial court may, motu proprio or on motion, dismiss the appeal for having been taken out of time or for non-payment of the docket and other lawful fees within the reglementary period. (As amended by A.M. No. 00-2-10-SC, May 1, 2000.)
Rule 41, Section 13 — Dismissal of appeal. Read the full provision →
The trial court's power before transmittal
Prior to the transmittal of the original record, or the record on appeal, to the appellate court, the trial court itself retains the power to dismiss the appeal, acting either on its own motion or on a motion filed by one of the parties, without having to wait for the Court of Appeals to take the matter up first. This authority exists specifically at that pre-transmittal stage, giving the trial court a narrow but useful window to weed out appeals that never should have proceeded in the first place.
The two grounds for dismissal
That dismissal power is limited to two specific grounds: the appeal having been taken out of time, meaning it was not filed within the period the Rules allow, or the non-payment of the docket and other lawful fees within the reglementary period set for paying them. Both grounds are essentially timeliness-based, concerned with whether the appellant met the deadlines the Rules impose, rather than with the merits of the appeal itself.
The cutoff point, and why it matters
This particular power belongs to the trial court only up until the record is actually transmitted; once transmittal happens, dismissal on these grounds becomes a matter for the appellate court instead. Keeping this power at the trial court level beforehand lets defects in timeliness or fee payment be caught and resolved early, without waiting on the appellate court to take up a case that never should have gone up in the first place.
What this power does not reach
The trial court's dismissal power here is confined to the two timeliness grounds — a late notice of appeal or unpaid docket fees — and does not extend to weighing the merits of the appeal itself. A trial court cannot use this provision to dismiss an appeal because it disagrees with the appellant's arguments; questions about the substance of the appeal remain for the Court of Appeals to decide once the record actually reaches it.