Philgreen Trading Construction Corporation v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Philgreen Trading Construction Corporation (Philgreen) was the highest bidder for a property foreclosed by United Coconut Planters Bank (UCPB). They entered into a Contract to Sell, with Philgreen depositing P1.4 million and agreeing to pay the balance of P11.6 million within ninety (90) days. Philgreen took possession, but later discovered the property was sequestered by the Philippine Commission on Good Government. Philgreen filed a case for specific performance and rescission (Civil Case No. 88-477) seeking UCPB to clear the sequestration before full payment. UCPB, in turn, filed an ejectment case (Civil Case No. 93-526) due to Philgreen's failure to pay the balance. Procedural History: The Metropolitan Trial Court ruled in favor of UCPB in the ejectment case. Philgreen appealed to the Regional Trial Court (RTC), Branch 150. Before the RTC, Philgreen moved to consolidate the ejectment appeal with the specific performance case or, alternatively, to suspend proceedings in the ejectment case pending resolution of the specific performance case. The RTC denied consolidation but suspended proceedings in the ejectment case, finding the specific performance case determinative of the ejectment issues. UCPB moved for reconsideration, which was denied. UCPB then filed a motion to reopen the case with a motion to resolve a motion for execution pending appeal. The RTC denied this motion, deeming the motion to reopen as a prohibited second motion for reconsideration and stating the motion for execution was not before it. UCPB filed a petition for certiorari with the Court of Appeals (CA). The Petition: The Court of Appeals granted UCPB's petition, reversing the RTC's orders and finding that the pendency of the specific performance case was not a bar to the ejectment case. Philgreen then filed the present petition with the Supreme Court, questioning the timeliness of UCPB's certiorari petition before the CA.
Issue(s)
Whether the Court of Appeals erred in not dismissing UCPB's petition for certiorari for being filed out of time. Whether the RTC correctly suspended the proceedings in the ejectment case pending resolution of the specific performance case.
Ruling
The petition is denied, and the decision of the Court of Appeals is affirmed. Costs against petitioner.
Ratio Decidendi
On the timeliness of the certiorari petition: The Court clarified that while a three-month period is generally considered reasonable for filing a petition for certiorari, it is not an absolute rule. The operative phrase is "reasonable period," which depends on the circumstances. The RTC's order of February 8, 1994, denying UCPB's motion to reopen and motion for execution pending appeal, was the proper reckoning point for the certiorari petition. This is because the order of June 4, 1993, suspending proceedings, was an interlocutory order, and the prohibition against a second motion for reconsideration applies only to final judgments and orders. UCPB received the February 8, 1994 order on March 1, 1994, and filed its certiorari petition on April 26, 1994, which is less than two months later, thus falling within a reasonable period. The Court also noted that the motion to resolve the motion for execution pending appeal was a new matter before the RTC, not a prohibited second motion for reconsideration. On the suspension of ejectment proceedings: The Court held that the RTC erred in suspending the proceedings in the ejectment case. While the specific performance case might be related, it does not automatically warrant the suspension of an ejectment case, which is a summary proceeding designed to restore possession of a property. The RTC's finding that the specific performance case was "unavoidably determinative" of the ejectment case was an overreach, as the issue in ejectment is primarily physical possession, not ownership or the validity of the contract to sell, which are issues in the specific performance case. The pendency of another case, involving different issues and parties, should not generally impede the progress of an ejectment suit.
Main Doctrine
A petition for certiorari must be filed within a reasonable period, typically three months, from receipt of the questioned order. However, this period is a yardstick, and courts may entertain petitions filed beyond this period if warranted by justice and laches has not set in. The prohibition against a second motion for reconsideration applies to final judgments and orders, not interlocutory ones.