De Roy v. Court of Appeals
REITERATIONFacts
The Antecedents: The firewall of a burned-out building owned by petitioners collapsed, destroying the tailoring shop occupied by the family of private respondents. This incident resulted in injuries to private respondents and the death of their daughter, Marissa Bernal. Private respondents had been warned by petitioners to vacate their shop due to its proximity to the weakened wall but failed to do so. Procedural History: The Regional Trial Court found petitioners guilty of gross negligence and awarded damages. The Court of Appeals affirmed the trial court's decision in toto. Petitioners received the appellate court's decision on August 25, 1987. On September 9, 1987, the last day of the fifteen-day period to file an appeal, petitioners filed a motion for extension of time to file a motion for reconsideration. This motion was denied by the Court of Appeals on September 30, 1987. Petitioners then filed a motion for reconsideration on September 24, 1987, which was denied on October 27, 1987. The Petition: Petitioners filed a special civil action for certiorari seeking to nullify the resolutions of the Court of Appeals denying their motion for extension and their motion for reconsideration.
Issue(s)
Whether the Court of Appeals committed a grave abuse of discretion in denying petitioners' motion for extension of time to file a motion for reconsideration. Whether the Court of Appeals committed a grave abuse of discretion in directing the entry of judgment. Whether the Court of Appeals committed a grave abuse of discretion in denying petitioners' motion for reconsideration. Whether the Court of Appeals erred in affirming the trial court's decision holding petitioners liable under Article 2190 of the Civil Code. Whether the doctrine of "last clear chance" is applicable to the case.
Ruling
The Supreme Court resolved to DENY the instant petition for lack of merit.
Ratio Decidendi
On the denial of the motion for extension and reconsideration: The Court held that the Court of Appeals did not commit a grave abuse of discretion. It correctly applied the rule established in Habaluyas Enterprises, Inc. v. Japzon, which states that the fifteen-day period for appealing or filing a motion for reconsideration cannot be extended. This rule was clarified by the Court en banc to be strictly enforced, with a one-month grace period from May 30, 1986, expiring on June 30, 1986, during which the prohibition against extensions was not yet strictly enforceable. Petitioners' motion for extension was filed on September 9, 1987, which was well beyond the expiration of this grace period. Therefore, the motion for extension was correctly denied as it was filed out of time. The Court also emphasized that ignorance of the law by counsel is not an excuse, and lawyers have a duty to keep abreast of Supreme Court decisions. This issue is addressed in the ratio for the first issue. This issue is addressed in the ratio for the first issue. On the affirmation of the trial court's decision under Article 2190 of the Civil Code: The Court found no error in the Court of Appeals affirming the trial court's decision. Article 2190 of the Civil Code provides that the proprietor of a building or structure is responsible for damages resulting from its collapse if due to lack of necessary repairs. The facts indicated that the collapse of the firewall, owned by the petitioners, caused the damage, thus making them liable under this provision. The Court reiterated that the proprietor's liability arises from the failure to undertake necessary repairs to prevent collapse. On the inapplicability of the "last clear chance" doctrine: The Court rejected petitioners' argument that the private respondents had the "last clear chance" to avoid the accident by heeding the warning to vacate. The Court clarified that the doctrine of "last clear chance," typically applied to vehicular accidents, is inapplicable to this case. The collapse of the building structure due to lack of repairs falls under the specific liability imposed by Article 2190 of the Civil Code, and the concept of a "last clear chance" to avoid the consequence of such structural failure is not a valid defense in this context. The focus remains on the proprietor's duty to maintain the building's integrity.
Main Doctrine
A motion for extension of time to file a motion for reconsideration cannot be granted if filed beyond the grace period established for the strict enforcement of the rule prohibiting such extensions, as clarified in Habaluyas Enterprises, Inc. v. Japzon.