Ram's Studio And Photographic Equipment, Inc. v. Court Of Appeals
REITERATIONFacts
The Antecedents: Private respondent Gina Cynthia Hernal contracted petitioner RAM's Studio and Photographic Equipment, Inc. (RAM's) for video coverage of her wedding. RAM's photographers failed to arrive on time, causing a delay in the ceremony. Furthermore, the delivered videotape was damaged, showing only a brownish-black screen with silhouettes for the first thirty minutes. RAM's offer to retake the damaged portion was rejected. Procedural History: Private respondents filed a complaint for damages against RAM's. RAM's failed to file an answer within the extended period and was declared in default. After presenting evidence ex-parte, the Regional Trial Court (RTC) rendered a decision in favor of the private respondents, awarding actual, moral, and exemplary damages, attorney's fees, and costs. RAM's counsel received the decision on April 10, 1996. On April 26, 1996, one day after the fifteen-day reglementary period for appeal had lapsed, RAM's filed a motion for new trial. The RTC initially granted the motion for new trial, citing that the motion was filed within the period for a petition for relief from judgment, and later denied private respondents' motion for reconsideration. Private respondents elevated the matter to the Court of Appeals (CA). The Petition: The CA set aside the RTC orders, ruling that RAM's motion for new trial was filed after the judgment had become final and executory, as it was filed one day late. RAM's motion for reconsideration was denied, leading to the instant petition for review before the Supreme Court.
Issue(s)
Whether the motion for new trial filed by petitioner was timely. Whether the Court of Appeals erred in setting aside the orders of the lower court granting petitioner's motion for new trial, considering the finality of the lower court's judgment and the arguments presented for a new trial.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the timeliness of the motion for new trial: The Court reiterated that perfecting an appeal within the legal period is mandatory and jurisdictional. Failure to do so renders the judgment final. Petitioner's counsel received the decision on April 10, 1996, and the motion for new trial was filed on April 26, 1996, one day late. Therefore, the judgment became final. Service to counsel is notice to the client, absent formal withdrawal. The reckoning period is April 10, 1996, not April 11, 1996. Even if timely, the grounds (traffic, equipment malfunction, false promises) were not meritorious. On the Court of Appeals' decision and the finality of judgment: A final judgment is immutable except for clerical errors. Since the motion for new trial was untimely, the case was final before reaching the Court of Appeals. Consequently, the award of damages, having become final, could no longer be modified. The Court of Appeals, therefore, did not err in setting aside the lower court's orders, as the judgment had already become final and executory.
Main Doctrine
Failure to perfect an appeal within the reglementary period renders the judgment final and executory, and this procedural bar cannot be trifled with, even by the Supreme Court. Service of notice to the counsel of record is considered notice to the client, and in the absence of a formal withdrawal or substitution, the court will assume the counsel of record continues to represent the client, making their receipt of notice the reckoning point for the reglementary period.