Delos Santos v. Elizalde
REITERATIONFacts
The Antecedents: Petitioners initiated a complaint for quieting of title, damages, and attorney's fees concerning four adjoining lots in Boracay Island, claiming ownership as heirs of Mariano delos Santos. Respondents, including the Elizalde spouses and various members of the delos Santos and Casimero families, asserted their own claims to the property, either through purchase from other heirs or as rightful inheritors. The Regional Trial Court (RTC) ultimately declared intervenors Jesus and Rosita delos Santos as lawful owners of two-thirds of the disputed land, and respondent Fred Elizalde as owner of the remaining one-third, while dismissing the petitioners' complaint and the Casimeros' intervention. Procedural History: Following the RTC's adverse decision, both the petitioners and respondent Fred Elizalde appealed to the Court of Appeals (CA). The CA issued a notice to file briefs, and petitioners filed multiple motions for extension to submit their brief. Meanwhile, respondent Elizalde, having reached an amicable settlement, moved to withdraw his appeal. Subsequently, petitioners' counsel filed a motion to withdraw their appeal, citing an amicable settlement between petitioners and respondents delos Santos. The CA, considering the failure to file briefs and the motions to withdraw, dismissed the appeals. Petitioners later sought reconsideration, alleging lack of knowledge of the decision and disputing the validity of the settlement and the withdrawal of their appeal. The CA denied this motion, finding it filed out of time. The Petition: This petition for review on certiorari under Rule 45 of the Rules of Court seeks to annul the CA's dismissal of their appeal and its denial of their motion for reconsideration. Petitioners argue that their motion for reconsideration was timely filed, as the reglementary period should be counted from their actual knowledge of the decision, not from their former counsel's receipt. They also contend that the CA erred in dismissing their appeal based on an alleged settlement and withdrawal, asserting the settlement was forged and they never authorized the withdrawal. Furthermore, they claim their appeal had merit and that the CA's denial of their motion for reconsideration, even if slightly late, was unjust and inequitable, especially given their counsel's alleged negligence and their own lack of participation in the settlement.
Issue(s)
Whether the Court of Appeals erred in denying admission to petitioners’ Motion for Reconsideration for having been filed nine (9) days late. Whether the Court of Appeals erred in dismissing petitioners’ appeal and considering it withdrawn, given the alleged invalidity of the amicable settlement agreement. Whether the Supreme Court can act as a trier of facts regarding the alleged forgery of signatures and non-payment of consideration in the settlement agreement.
Ruling
The petition is denied. The May 11, 1999 Decision and the January 31, 2000 Resolution of the Court of Appeals are affirmed.
Ratio Decidendi
On the timeliness of the Motion for Reconsideration: The Supreme Court reiterated that the reglementary period for filing a motion for reconsideration is reckoned from the date of receipt of the judgment by the counsel of record, which is considered notice to the parties. In this case, the counsel of record, Atty. Victoriano, received the CA Decision on May 24, 1999. Therefore, the 15-day period to file a motion for reconsideration expired on June 8, 1999. The motion filed on June 17, 1999, was nine days late and correctly rejected by the CA. The Court emphasized that service upon the parties' counsels of record is tantamount to service upon the parties themselves, as parties generally lack the knowledge of procedural rules. Even if a substitution of counsel occurred, the period would still be reckoned from the receipt by the former counsel unless the substitution was properly effected and noticed. The petitioners' claim that they learned of the decision only on June 2, 1999, was disregarded as the reglementary period is tied to counsel's receipt. On the dismissal of the appeal and the alleged invalidity of the settlement: The Court found no reversible error in the CA's dismissal of the appeal. The CA's decision explicitly stated that the dismissal was for failure to file appellant's briefs, in accordance with the joint manifestation and motion, and the ex-parte motion to withdraw appeal. The Court noted that petitioners' former counsel sought multiple extensions for filing the brief, totaling 180 days, and ultimately filed a motion to withdraw the appeal. The Court found that petitioners were guilty of inexcusable negligence, not only in failing to monitor the progress of their case for an extended period but also in relying solely on their counsel. The Court distinguished this case from Ginete v. Court of Appeals, where the counsel's negligence was without participatory negligence from the client; here, the petitioners' lack of diligence was a significant factor. The Court stressed that parties should not leave the entire business of litigation solely to their counsels and must provide full support and monitor developments. On the Supreme Court as a trier of facts: The Court held that it is not a trier of facts and does not normally re-examine evidence, especially concerning the alleged forgery of signatures in the Undertaking or Agreement and the non-payment of consideration. The Court found that the issues raised by the petitioners, including the authenticity of documents and the validity of the settlement, fall under questions of fact. Since the case did not fall under any of the recognized exceptions where the Supreme Court may review factual findings (e.g., grave abuse of discretion, misapprehension of facts, conflicting findings), these factual issues could not be entertained. The Court concluded that the petitioners' claim of forgery and non-payment was a factual matter that should have been resolved by the CA, but it was not reached due to the dismissal of the appeal. Therefore, the ownership issue became a non-issue before the Supreme Court.
Main Doctrine
The reglementary period for filing a motion for reconsideration is reckoned from the date counsel of record receives notice of the judgment, not from the date the party-litigant obtains knowledge thereof. Parties are bound by the negligence of their counsel, and diligence requires them to monitor the progress of their cases.