Spouses Ruben and Luz Galang v. Court of Appeals and Leonardo de Leon
REITERATIONFacts
The Antecedents: This case originated from an ejectment suit filed by private respondent Leonardo de Leon against petitioners, Spouses Ruben and Luz Galang, who were lessees of one unit in a 6-door apartment owned by de Leon. The Metropolitan Trial Court of Manila ruled in favor of de Leon, ordering the Galangs to vacate the premises, pay monthly rent from September 1985 until vacation, and cover attorney's fees. Procedural History: The Galangs appealed the Metropolitan Trial Court's decision to the Regional Trial Court of Manila, which affirmed the lower court's ruling. Subsequently, the Galangs filed a petition for review with the Court of Appeals. The Court of Appeals initially gave the petition due course but later dismissed it due to the Galangs' failure to pay the required P80.40 for costs within the stipulated three-day period. The appellate court also denied their motion for an extension of time to pay costs, deeming it filed late, and subsequently denied their motion for reconsideration. The Petition: The Spouses Galang are now before the Supreme Court seeking to set aside the resolutions of the Court of Appeals that dismissed their petition for review and denied their motions. They argue that the Court of Appeals erred in dismissing their petition for non-payment of costs within three days and in denying their motion for extension, contending that the Rules of Court do not mandate such a short period for cost payment and that the period is too brief for counsel to coordinate with clients. They also assert that the Court of Appeals should have admitted their payment of costs and decided the case on its merits.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in dismissing the petition for review for failure to pay costs within the reglementary period. Whether the Court of Appeals erred in denying the motion for extension of time to pay costs for being filed one day late. Whether the Court of Appeals correctly ruled on the validity of the lessor's need to repossess the premises under Batas Pambansa Blg. 25.
Ruling
The petition is DISMISSED for lack of merit. The decision is immediately executory. Costs against petitioners.
Ratio Decidendi
On the dismissal of the petition for non-payment of costs: The Court held that the dismissal was not an error or grave abuse of discretion. The CA acted in accordance with its en banc Resolution of August 12, 1971, which was adopted by Section 22(2) of the Interim Rules and Guidelines. This resolution clearly states that upon failure to deposit the amount for costs within three days from notice, the petition shall be dismissed. Petitioners' motion for extension was filed one day after the due date, rendering it out of time. The Court reiterated that while litigation should not be a game of technicalities, procedural rules are essential for the orderly administration of justice and cannot be ignored at will. The claim that petitioners were not furnished a copy of the resolution is unavailing, as notice to counsel is notice to the client. On the denial of the motion for extension: The Court found no error in the denial of the motion for extension. The motion was filed one day beyond the reglementary period. Furthermore, even if the extension were granted, the actual payment of costs was made five days late from the expiration of the supposed extension. This demonstrated a lack of serious intention to comply with the CA's order in good faith. The Court emphasized that procedural rules are not to be belittled, and their relaxation requires the most persuasive of reasons, which were absent in this case. On the validity of the lessor's need to repossess: The Court affirmed the CA's ruling that the lessor's need to repossess the property for the use of his immediate family was a valid ground for ejectment under Section 5(c) of Batas Pambansa Blg. 25. The records showed that the private respondent's sister and parents were living in a small rented apartment, and the leased premises were intended for them. The Court recognized the legitimate need of the private respondent to provide his family with a decent place to stay. It was also not clearly proven that the private respondent owned other properties in Manila. The Court reiterated that a month-to-month lease is a lease with a definite period, and if the lessor needs the property for statutory grounds, the lease is considered terminated after proper notice. The demand to vacate was made as early as June 7, 1985, for September 15, 1985, and the ejectment case was filed thereafter.
Main Doctrine
The dismissal of a petition for review by the Court of Appeals due to non-payment of costs within the reglementary period, even if the motion for extension was filed one day late, is a valid exercise of its discretion, as procedural rules must be followed to ensure orderly administration of justice, and notice to counsel is notice to the client.