Yaneza v. De Jesus
REITERATIONFacts
The Antecedents: Petitioner is the registered owner of Lot 2730-A acquired on 1990-06-19. Respondents own adjacent Lot 2732 and used a portion of Lot 2730-A as an access road. Beginning in 1995 petitioner corresponded with respondents offering either sale of his lot or a perpetual easement; on 1995-10-20 the parties executed a Deed of Absolute Sale covering 175 sq. m of petitioner’s lot for P20,000 with terms regarding area, consideration, payment of costs, and use as a right of way. On 1996-09-12 petitioner executed a unilateral Deed of Cancellation. Respondents countered that they had purchased the area earlier from a prior owner, that they paid P20,000 and later an additional P40,000 after renegotiation to cover 280 sq. m, and that the parties in fact entered into a subsequent agreement covering the larger area which was partially consummated by possession and improvements. Procedural History: Petitioner filed a Complaint for Cancellation of Contract in the Municipal Circuit Trial Court (MCTC) on 1997-04-22. Respondents answered with counterclaims. After trial, on 1999-09-06 the MCTC dismissed petitioner’s complaint and granted respondents’ counterclaims, ordering among others that petitioner execute a new deed reflecting the 280 sq. m and awarding various damages. On 2001-01-05 the Regional Trial Court (RTC), Morong, Rizal affirmed the MCTC decision but deleted the monetary awards. Petitioner sought timely review before the Court of Appeals (CA). On 2001-02-22 petitioner filed an Urgent Motion for Extension of Time to File Petition for Review which the CA denied in a resolution dated 2001-02-28 as having been filed one day late; subsequent motions were denied by the CA on 2001-07-25. Petitioner filed this petition for certiorari and prohibition under Rule 65 before the Supreme Court. The Petition: Petitioner urged the Supreme Court to grant relief on multiple grounds: that the CA should have given due course to his late-filed motion in light of the circumstances; that the RTC decision was not rendered or written as required by the 1987 Philippine Constitution and the Rules of Court; that the complaint lacked cause of action; and that he cannot be compelled to execute a deed against his will in violation of due process and principles against unjust enrichment.
Issue(s)
Whether the petition should be given due course in the light of the circumstances affecting the timeliness of the filing thereof. Whether the appealed decision of the Regional Trial Court was rendered and written as required by the 1987 Philippine Constitution and the Rules of Court. Whether the plaintiff has no cause of action. Whether the petitioner may be compelled to execute a deed of conveyance against his will and in violation of his constitutional right against deprivation of property without due process of law, and the civil law against unjust enrichment.
Ruling
The petition is DISMISSED. The assailed Court of Appeals Resolutions dated 2001-02-28 and 2001-07-25 are AFFIRMED. The Court held that the CA did not commit grave abuse of discretion in denying the late Motion for Extension of Time, that the petitioner's complaint for cancellation was properly dismissed for lack of substantial breach and because the earlier deed of sale had been superseded by a subsequent agreement covering 280 sq. m which was consummated, and that petitioner may be compelled to execute the corresponding deed in accordance with Article 1357 of the Civil Code.
Ratio Decidendi
On Issue 1 (Timeliness / Motion for Extension): The Supreme Court held that perfection of an appeal in the manner and within the period prescribed by law is mandatory and jurisdictional. The Court explained that a motion for extension of time must be filed prior to the expiration of the reglementary period because after expiration there is no longer any period to extend and the judgment becomes final and executory. Once finality has attached, the appellate court lacks jurisdiction to entertain or modify the judgment, and denial of a belated motion for extension does not constitute grave abuse of discretion. The petitioner bore the burden of proving an exceptionally meritorious reason to deviate from the reglementary period, which he failed to do. Consequently, the CA properly denied the motion filed after the lapse of the prescribed period and dismissed the appeal for lack of jurisdiction. On Issue 2 (Form and Requirements of RTC Decision): The Court found no reversible defect in the RTC's rendering and writing of its decision as complained by petitioner. The opinion notes that petitioner did not demonstrate any particular constitutional or Rules of Court violation that would justify relief under Rule 65. The absence of such a showing means the challenged RTC decision stood as properly rendered and sufficient for appellate review procedures. Moreover, because the procedural posture resulted in finality when the extension motion was filed late, any alleged infirmity in form would not avail petitioner to obtain relief from the appellate tribunal. The Court reiterated that Rule 65 is not a substitute for an appeal and cannot be used to remedy mere errors of judgment. On Issue 3 (Cause of Action for Cancellation / Rescission): The Court reasoned that rescission is available only for a substantial and fundamental breach that defeats the object of the contract, not for slight or casual breaches. The Court examined the allegations and evidence and concluded that the respondents' acts did not constitute such substantial breach. Further, the Court emphasized that rescission presupposes an existing valid and subsisting obligation; it would be futile to rescind a contract that no longer exists. The Supreme Court found that the original 175 sq. m deed of sale had been superseded by a subsequent agreement covering 280 sq. m, evidenced by payments admitted by petitioner and by the parties' conduct and acknowledgment receipt. Therefore, the claim for cancellation of the original contract failed both because the breach alleged was not substantial and because the contract sought to be rescinded had been novated. On Issue 4 (Compulsion to Execute Deed / Statute of Frauds): The Court held that the new contract, though oral and not evidenced by a written instrument, was enforceable because it had been at least partially or totally consummated by payment and possession. The Statute of Frauds affects enforceability but not validity; where a contract has been consummated, the requirement of writing for enforceability does not apply in the same manner. Citing Article 1357 of the Civil Code, the Court stated that once the existence of a contract has been established, the party bound may be compelled to observe the required form and execute the corresponding document. Therefore, petitioner could be compelled to execute a deed reflecting the agreement covering 280 sq. m, and his constitutional and unjust enrichment arguments did not justify nullifying the consummated agreement.
Main Doctrine
Perfection of an appeal within the reglementary period is mandatory and jurisdictional; a motion for extension filed after lapse of the period cannot be granted. Rescission requires a substantial breach; an oral contract that has been partially or totally consummated may be enforced despite the Statute of Frauds, and a party may be compelled to execute the corresponding written instrument under Article 1357 of the Civil Code.