Cosmo Entertainment Management v. La Ville Commercial
REITERATIONFacts
1. The Antecedents: The respondent, La Ville Commercial Corporation, is the registered owner of a commercial property in Makati City. On March 17, 1993, it entered into a seven-year lease agreement with petitioner Cosmo Entertainment Management, Inc. The petitioner took possession of the property but subsequently suffered business reverses, leading to a default in rental payments starting in September 1996. The respondent made demands for payment and vacation of the premises, which the petitioner contested by proposing to offset its security deposit against the unpaid rentals. After negotiations failed, the respondent filed an illegal detainer case against the petitioner. 2. Procedural History: The Metropolitan Trial Court (MeTC) of Makati City ruled in favor of the respondent, ordering the petitioner to vacate the premises and pay accrued rentals and other charges. The petitioner appealed this decision to the Regional Trial Court (RTC) of Makati City, Branch 150. The RTC affirmed the MeTC's decision in its entirety, finding that the petitioner had breached the lease contract by failing to pay rentals and that the lessor's right to approve subleases was validly stipulated. The petitioner then filed a petition for review with the Court of Appeals (CA). 3. The Petition: The petitioner filed a petition for review on certiorari under Rule 45 of the Rules of Court, seeking to reverse the Court of Appeals' Resolution dated September 26, 2000, which dismissed its petition for review for being filed out of time. The petitioner argued that the CA erred in denying its petition, asserting that a second motion for extension of time is permissible and that procedural rules should be relaxed for substantial justice. The CA had granted an initial fifteen-day extension, which was non-extendible, and subsequently denied the petition when it was filed thirteen days beyond that extended period, despite a second motion for extension being filed.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for review for being filed out of time. Whether a second motion for extension of time to file a petition for review with the Court of Appeals is permissible under the Rules of Court. Whether technical rules of procedure should be relaxed in favor of substantial justice in this case; and on the merits of the underlying lease dispute.
Ruling
The petition is denied. The Resolutions dated September 26, 2000, and March 22, 2002, of the Court of Appeals in CA-G.R. SP No. 59819 are affirmed in toto.
Ratio Decidendi
On the issue of the timeliness of the petition for review: The Court held that Rule 42 of the 1997 Rules of Court governs the filing of petitions for review with the Court of Appeals. Section 1 of Rule 42 provides for an initial period of fifteen (15) days to file the petition, and allows for an additional period of fifteen (15) days only upon proper motion and payment of fees within the reglementary period. The rule explicitly states that no further extension shall be granted except for the most compelling reason and in no case to extend beyond fifteen (15) days. In this case, the CA granted an extension but expressly qualified it as a "non-extendible period." Therefore, Cosmo was bound to comply with this directive. On the permissibility of a second motion for extension: The Court reiterated that motions for extensions are not granted as a matter of right but in the sound discretion of the court. With greater reason, a second motion for extension, which is generally not granted except for the most compelling reason, requires a stronger justification. The petitioner's reason of "heavy volume of work and equally urgent filings" was not considered a compelling reason by the CA, and this Court has previously held that such reasons do not excuse a party for filing out of time. The CA's discretion in denying the second motion and subsequently dismissing the petition was therefore not erroneous. On the relaxation of technical rules for substantial justice and the merits of the underlying lease dispute: While the Court may adopt a liberal stance in applying procedural rules exceptionally, the circumstances in this case did not warrant such an exception. The Court emphasized that procedural rules are not mere technicalities to be ignored for the convenience of a party. They are essential for the orderly and speedy administration of justice. The petitioner's failure to comply with the clear directive of the CA regarding the non-extendible period for filing the petition meant that the petition was filed out of time, and the CA was justified in dismissing it. The Court found no cogent reason to depart from the findings of the lower courts. Both the MeTC and the RTC uniformly concluded that under the contract of lease, La Ville, as the owner-lessor, reserved its right to approve any sublease. Cosmo, by voluntarily giving its consent to this stipulation, was bound by it under the principle of mutuality of contracts. Furthermore, Cosmo's failure to pay monthly rentals constituted a clear breach of the contract, justifying its ejectment from the leased premises. The factual disquisitions of the lower courts were binding on the Supreme Court.
Main Doctrine
A second motion for extension of time to file a petition for review with the Court of Appeals is generally not granted except for the most compelling reason, and the Court of Appeals may deny a petition filed beyond the extended period, even if a second motion for extension was filed, if the reason provided is not considered compelling.