German Management & Services, Inc. v. Court of Appeals
REITERATIONFacts
The Antecedents: This case originated from an unlawful detainer suit filed by petitioner German Management and Services, Inc. (GERMAN) against private respondent Ruperto Eltanal. GERMAN had previously filed a similar suit in 1972, which was dismissed and later affirmed on appeal. Despite the prior dismissal and finality of that judgment, GERMAN filed a second unlawful detainer case in 1984, asserting the same grounds. Procedural History: The Metropolitan Trial Court dismissed the second unlawful detainer case, citing Batas Pambansa Blg. 877, the prohibition against ejectment at the end of each month, the case being barred by prior judgment, and the finding that the lessee had not subleased the premises. The Regional Trial Court affirmed this decision in its entirety. Petitioner then filed a motion for reconsideration, arguing that a month-to-month lease is for a definite period and thus not covered by Batas Pambansa Blg. 877, but this motion was denied. The Petition: Petitioner seeks review of the Court of Appeals' decision which dismissed their appeal due to tardy filing. The petition argues that the Court of Appeals erred in holding the petition for review was filed late and in not ruling that a month-to-month lease is for a definite period, thus allowing ejectment under Article 1673(1) of the New Civil Code. The petition was filed before the Intermediate Appellate Court on June 3, 1986, after receiving the denial of the motion for reconsideration on May 19, 1986, which was beyond the remaining eleven days of the reglementary period.
Issue(s)
Whether the Respondent Court of Appeals erred in holding that the petition for review was tardily filed. Whether the Respondent Court of Appeals erred in not holding that a lease contract on a month-to-month basis is for a definite period, but this issue is moot due to the tardy filing of the petition.
Ruling
The petition is DENIED for utter lack of merit. The decision of the Court of Appeals dismissing the appeal on the ground of tardy filing is affirmed.
Ratio Decidendi
On the issue of tardy filing: The Supreme Court affirmed the ruling of the Court of Appeals that the petition for review was tardily filed. The Court reiterated the principle that a final judgment or order of a regional trial court in an appeal from a metropolitan trial court may be appealed to the Court of Appeals through a petition for review within fifteen days. The filing of a motion for reconsideration interrupts the period to appeal, but the remaining period resumes upon receipt of the order denying the motion. In this case, the petitioner received the denial order on May 19, 1986, leaving only eleven days of the reglementary period. The petition for review was filed on June 3, 1986, which was beyond the allowed period, rendering the decision of the respondent court final and executory. The Court noted that petitioner never sought an extension of time to file the petition. On the issue of month-to-month lease being for a definite period: While the Court did not directly rule on the merits of whether a month-to-month lease is for a definite period, it was rendered moot by the tardy filing of the petition. The Court's primary focus was on the procedural defect of late filing, which precluded it from reviewing the substantive issues raised by the petitioner. The principle of finality of judgments dictates that once a decision becomes final and executory due to procedural lapses, the appellate court loses jurisdiction to pass upon the merits of the case.
Main Doctrine
A petition for review filed beyond the reglementary period, even after a motion for reconsideration has been filed and denied, is considered tardy and renders the decision final and executory, barring further review.