Argel v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from a Regional Trial Court (RTC) decision in Special Proc. No. 92-62305, which ordered respondent Rosendo G. Guevara to deliver a substantial sum representing his son Victorio Guevara's presumptive legitime from his mother's estate, provide monthly support for Victorio's education, and pay damages and attorney's fees to petitioner Ma. Imelda Argel. The RTC decision also stipulated penalties for non-compliance, including interest and re-appraisal of properties. 2. Procedural History: Petitioner Ma. Imelda Argel received the RTC decision on September 11, 1995. On September 26, 1995, she filed a motion for extension to file a motion for reconsideration, which was granted by the RTC on December 12, 1995, along with an amendment to the original decision increasing the awarded amounts. Meanwhile, respondent Rosendo G. Guevara filed a Notice of Appeal on October 2, 1995, and later an amended notice of appeal. He also filed a petition for certiorari and prohibition with the Supreme Court, which was referred to the Court of Appeals (CA). The CA granted the petition for certiorari, setting aside the RTC's order of December 12, 1995. Petitioner's motion for reconsideration of the CA decision was denied. 3. The Petition: This petition for review, filed under Rule 45 of the Rules of Court, assails the CA's decision and resolution. Petitioner argues that the CA erred in holding that the trial court acted with grave abuse of discretion in admitting her motion for reconsideration, contending the trial court had inherent authority to do so, especially given her status as an Australian resident. Petitioner also claims the CA erred in not finding the respondent guilty of forum shopping for simultaneously pursuing an appeal and a certiorari petition. The petition seeks to reverse the CA's decision and reinstate the amended judgment of the trial court.
Issue(s)
Whether the Court of Appeals erred and abused its discretion in granting respondent's petition to reverse the trial court's order allowing petitioner's motion for reconsideration. Whether or not private respondent was guilty of forum shopping.
Ruling
The petition is dismissed for lack of merit. The assailed decision and resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the first issue (Grave Abuse of Discretion in admitting the motion for reconsideration): The Supreme Court affirmed the Court of Appeals' finding that the trial court committed grave abuse of discretion. The Court reiterated the doctrine laid down in Habaluyas v. Japzon and clarified in Supreme Court Circular No. 10-86, which strictly prohibits motions for extension of time to file a motion for new trial or reconsideration in all courts except the Supreme Court. The Court emphasized that neither jurisprudence nor the procedural rules provide for exceptions, even in cases involving foreign residents. The fact that petitioner was a resident of Australia was not stated in the motion for extension and does not create an exception to the rule. The Court found no reason for the trial court to be unaware of the Habaluyas ruling, which had been promulgated more than twelve years prior and reiterated numerous times. Therefore, the trial court's act of granting the extension and entertaining the motion for reconsideration was a violation of a clear and established rule, constituting grave abuse of discretion. On the second issue (Forum Shopping): The Supreme Court found no reversible error in the Court of Appeals' refusal to declare private respondent guilty of forum shopping. The Court defined forum shopping as the institution of two or more cases grounded on the same cause of action, seeking favorable disposition from different tribunals. It clarified that the private respondent's filing of a special civil action for certiorari and a notice of appeal did not constitute forum shopping because the issues involved were distinct. The certiorari petition sought to nullify the trial court's order of December 12, 1995, for alleged grave abuse of discretion, while the appeal assailed the merits of the trial court's judgment of August 31, 1995, and its subsequent order of December 12, 1995. The Court distinguished this from cases where forum shopping was found, such as Silahis International Hotel, Inc. v. National Labor Relations Commission, where the issues were interrelated. The Court noted that the certiorari sought to prevent a grave abuse of discretion (an act without or in excess of jurisdiction), whereas the appeal sought to correct errors of judgment (non-jurisdictional errors). The Court also pointed out that private respondent did not conceal the pendency of his appeal when filing the certiorari petition, unlike in Collado v. Hernando. Therefore, the two remedies were distinct and not availed of in the alternative or in succession, consistent with Oriental Media, Inc. v. Court of Appeals.
Main Doctrine
A motion for extension of time to file a motion for reconsideration is a prohibited motion, and the trial court commits grave abuse of discretion in granting such a motion, even if the party is a foreign resident, as the rules do not provide for exceptions. Furthermore, filing a petition for certiorari to assail an interlocutory order while an appeal on the main judgment is pending does not constitute forum shopping if the issues are distinct and the appellate court is aware of both proceedings.