Aprieto v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from a complaint for collection of a sum of money filed by Candido Lim Kim Po against Benjamin S. Aprieto and Alfredo S. Aprieto. The claim arose from the sale of two marine crankshafts to the Aprieto brothers, who were doing business under the name and style of "BSA Enterprises." The defendants denied the material allegations of the complaint. 2. Procedural History: The Regional Trial Court of Manila, on May 20, 1982, rendered a judgment in favor of the private respondent, ordering the defendants to pay P180,000.00 plus interest, P25,000.00 as attorney's fees, and costs. The petitioners appealed this decision to the Court of Appeals. On September 17, 1985, the Court of Appeals affirmed the trial court's decision, reducing the attorney's fees to P15,000.00. Petitioners received this decision on September 23, 1985. On the last day of their reglementary period, October 8, 1985, petitioners' counsel filed a motion for an extension of thirty days to file a motion for reconsideration, citing personal bereavement. This motion was denied by the appellate court on October 18, 1985, invoking the doctrine in Habaluyas Enterprises, Inc. et al. v. Mariano Japson et. al. Petitioners received this denial on October 30, 1985. The appellate court declared its decision final and executory on November 15, 1985, and an entry of judgment was made on January 15, 1986. The case was remanded for execution, and a writ of execution was issued on March 1, 1986, leading to a notice of levy and sale of petitioners' personal properties. 3. The Petition: The petitioners filed a petition for review with the Supreme Court, imputing grave abuse of discretion to the respondent appellate court for denying their motion for an extension of time to file a motion for reconsideration. Initially, the Supreme Court denied the petition for review on certiorari for being filed out of time and for late payment of legal fees. However, upon reconsideration, the Court granted the motion, gave due course to the petition, and required the parties to file their respective memoranda. Despite extensions, the petitioners failed to file their memorandum and did not provide any explanation or request further extensions. The Court issued a resolution requiring the petitioners' counsel to show cause for this failure and to comply with the memorandum filing requirement. Ultimately, due to the manifest lack of interest and gross negligence in pursuing the case, the Supreme Court dismissed the petition with double costs against the petitioners.
Issue(s)
Whether the respondent appellate court committed grave abuse of discretion amounting to excess of jurisdiction when it denied the motion for an extension of time to file a motion for reconsideration. Whether the petition for review on certiorari was filed out of time and whether the legal fees were paid on time.
Ruling
The petition is DISMISSED, with double costs against petitioners.
Ratio Decidendi
On the issue of grave abuse of discretion in denying the motion for extension: The Supreme Court held that the respondent appellate court did not commit grave abuse of discretion. The Court reiterated the prevailing doctrine that a motion for extension of time to file a motion for reconsideration is generally not allowed. The reason cited by the petitioners' counsel, being in mourning, was not considered an extraordinary circumstance that would warrant deviation from the rule. The Court emphasized that the reglementary period must be strictly observed to ensure the finality of judgments and the orderly administration of justice. Allowing such extensions would undermine the principle of immutability of judgments and lead to undue delays. The denial of the motion for extension was in line with established jurisprudence, specifically citing Habaluyas Enterprises, Inc. et al. v. Mariano Japson et al., which held that a motion for extension to file a motion for reconsideration is a prohibited pleading. On the timeliness of the petition and payment of legal fees: The Supreme Court noted that the petition for review on certiorari was filed out of time, and the legal fees were paid late. The due date for both was November 14, 1985, but the petition was filed and fees paid later. Even if the petition were considered timely, the Court found it to be without merit. The Court's initial resolution denying the petition on these grounds was reinstated after reconsideration, highlighting the procedural deficiencies that plagued the petitioners' pursuit of their case. The subsequent failure to file a memorandum, despite opportunities and warnings, further demonstrated a lack of interest and gross negligence, which the Court considered as grave abuse of its tolerance and a disregard for the judicial process.
Main Doctrine
A motion for extension of time to file a motion for reconsideration is generally not allowed, especially when invoking personal circumstances that do not constitute an extraordinary event, and failure to file within the reglementary period renders the decision final and executory. Gross negligence and disregard for judicial processes in pursuing a case can lead to dismissal and disciplinary action.