Mid-Islands Power v. Court of Appeals
REITERATIONFacts
The Antecedents: Oriental Mindoro Electric Cooperative, Inc. (ORMECO) entered into an Electric Supply Agreement (ESA) with Power One Corporation (Power One). Power One was permitted to install and operate an electric generating facility and to assign its rights to an affiliate or project company. Power One formed a joint venture, Mid-Islands Power Generation Corporation (Mid-Islands Power), to assume its rights and obligations under ESAs with ORMECO and Central Negros Electric Cooperative (CENECO). A Memorandum of Agreement (MOA) was executed, and Power One assigned its ESAs to Mid-Islands Power. Later, a Revised MOA was entered into, focusing on the ORMECO project and forming an "O & M Company" for operations. Business relations soured due to delays and financing issues. Power One alleged Mid-Islands Power's inability to fulfill commitments, leading to a reduction in power generation. Power One and Islands Grid barred Mid-Islands Power and MindoroTech from entering the Calapan Diesel Power Plant. Procedural History: Mid-Islands Power and MindoroTech filed a Complaint for injunction against Power One and others. The Pasig RTC issued a TRO and later a preliminary injunction, allowing Mid-Islands Power and MindoroTech to operate the plant. Concurrently, ORMECO filed a separate Complaint against Power One for specific performance, leading to a TRO and turnover of operations to ORMECO. The Pasig RTC issued a permanent injunction. Power One assailed the Pasig RTC's Order before the Court of Appeals (CA) via a Petition for Certiorari and Prohibition, arguing lack of territorial jurisdiction. The CA sustained the Pasig RTC's Order. Power One filed a Motion for Extension to file a Petition for Certiorari questioning the Pasig RTC's Order granting permanent injunction. The CA granted the motion, despite Mid-Islands Power's opposition based on A.M. No. 07-7-12-SC. The Petition: The Supreme Court is asked to determine if the CA committed grave abuse of discretion in granting Power One's Motion for Extension to file a petition for certiorari, considering the amendment under A.M. No. 07-7-12-SC which purportedly deleted the provision allowing extensions.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion, amounting to lack or excess of jurisdiction, in granting respondent Power One’s Motion for Extension to file a petition for certiorari. Whether the amendment under A.M. No. 07-7-12-SC, which deleted the provision allowing an extension of time to file a petition for certiorari under Rule 65, absolutely prohibits the granting of such extensions.
Ruling
The Petition is DISMISSED. The 23 December 2008 and 23 June 2009 Resolutions of the Court of Appeals in CA-G.R. SP No. 106511 are AFFIRMED.
Ratio Decidendi
On the issue of whether the Court of Appeals committed grave abuse of discretion in granting the Motion for Extension: The Court held that while A.M. No. 07-7-12-SC amended Section 4, Rule 65 of the Rules of Court by deleting the provision allowing extensions of time to file a petition for certiorari, this amendment was not intended to make such filing absolutely prohibited. The Court clarified in Domdom v. Sandiganbayan that the deletion did not ipso facto make motions for extension absolutely prohibited. Instead, such motions may still be allowed, subject to the sound discretion of the Court, and only under exceptional and meritorious cases. The present case was deemed exceptional due to the involvement of strong public interest concerning the operations of the Calapan Diesel Power Plant, which supplies electricity to Oriental Mindoro. The dispute had already led to reduced power generation and an impending brownout, necessitating the relaxation of procedural rules to serve substantial justice. Therefore, the CA's grant of the extension was found to be justifiable under these circumstances, and no grave abuse of discretion was committed. On the interpretation of A.M. No. 07-7-12-SC and the absolute prohibition of extensions: The Court reiterated that the amendment under A.M. No. 07-7-12-SC aimed to prevent the abuse of the certiorari remedy for delay. The deletion of the extension clause was to ensure a more expeditious disposition of cases. However, the Court emphasized that procedural rules are tools to facilitate justice and should not be applied rigidly to frustrate it. In Laguna Metts Corporation v. Court of Appeals, the Court explained that the deletion was to avoid unreasonable delay, but it did not explicitly prohibit extensions. The ruling in Domdom v. Sandiganbayan further clarified that without an express prohibition, motions for extension could still be considered in exceptional circumstances. The Court found that the present case presented such an exceptional circumstance, where the public interest in maintaining the power supply outweighed the strict adherence to the amended rule. The Court also noted that the Petition was filed within the 15-day extension requested, causing no significant prejudice to the substantive rights of the litigants.
Main Doctrine
The Court of Appeals may grant a motion for extension to file a petition for certiorari under Rule 65, even after the amendment introduced by A.M. No. 07-7-12-SC, in exceptional and meritorious cases, particularly when strong public interest is involved, to serve substantial justice.