Rivelisa Realty v. First Sta. Clara
REITERATIONFacts
The Antecedents: Rivelisa Realty, Inc. (Rivelisa) and First Sta. Clara Builders Corporation (First Sta. Clara) entered into a Joint Venture Agreement (JVA) for the construction and development of a residential subdivision. First Sta. Clara was to assume the horizontal development works on the remaining undeveloped portion within twelve months, and upon completion, 60% of the subdivided lots would be transferred to it. First Sta. Clara was also required to initially use its own resources amounting to P10,000,000.00 before claiming additional funds. During the project, First Sta. Clara ran out of funds, and Rivelisa shouldered part of the subcontractor's payment. First Sta. Clara expressed its intention to withdraw from the JVA. Rivelisa agreed to release First Sta. Clara, estimating its accomplishment at P4,000,000.00. First Sta. Clara insisted on a valuation of P4,578,142.10, with a net reimbursable amount of P3,000,000.00. Rivelisa agreed to reimburse P3,000,000.00, stating it was beyond its obligation under the JVA, but failed to pay despite demands. Procedural History: First Sta. Clara filed a complaint for rescission of the JVA and damages. Rivelisa asserted it was not obligated to pay as First Sta. Clara failed to comply with its initial funding obligation. The Regional Trial Court (RTC) dismissed the complaint and ordered First Sta. Clara to pay Rivelisa for actual expenses and damages. The Court of Appeals (CA) reversed the RTC, holding Rivelisa liable for First Sta. Clara's P3,000,000.00 accomplishments based on the principle of quantum meruit, as Rivelisa agreed to the dissolution of the JVA and reimbursement. The Petition: Rivelisa received the CA Decision on March 3, 2009. It filed a motion for a 15-day extension to file a motion for reconsideration on March 18, 2009. Rivelisa filed its motion for reconsideration on April 2, 2009. The CA denied the motion for extension, stating the 15-day period is non-extendible, and noted without action the motion for reconsideration. Subsequently, the CA denied the motion for reconsideration for being filed out of time. Rivelisa filed a petition for review on certiorari before the Supreme Court.
Issue(s)
Whether the Court of Appeals erred in finding that the 15-day reglementary period for the filing of a motion for reconsideration cannot be extended. Whether First Sta. Clara is entitled to be compensated for the development works it had accomplished on the project.
Ruling
The petition is bereft of merit. The Court affirmed the CA Decision and Resolutions, holding that the CA Decision had attained finality due to Rivelisa Realty's failure to file a motion for reconsideration within the 15-day reglementary period. The Court also upheld the CA's finding that First Sta. Clara is entitled to compensation for its accomplished works based on the principle of quantum meruit.
Ratio Decidendi
On the issue of the non-extendibility of the reglementary period for filing a motion for reconsideration: The Court reiterated the ruling in Habaluyas Enterprises v. Japzon and Rolloque v. CA, emphasizing that the 15-day period for filing a motion for reconsideration before the Court of Appeals is non-extendible. The filing of a motion for extension of time to file a motion for reconsideration does not toll the running of the period for the finality of the judgment. In this case, Rivelisa Realty filed a motion for extension, which was improper before the CA, and its subsequent motion for reconsideration was filed out of time. Consequently, the CA Decision became final and executory, and the CA correctly denied Rivelisa's motion for reconsideration. The Supreme Court also lost its appellate jurisdiction to review the decision due to the lapse of the reglementary period. On the entitlement to compensation based on quantum meruit: Even disregarding the procedural issue, the Court found substantive merit in First Sta. Clara's claim. The Court applied the principle of quantum meruit, which allows a contractor to recover the reasonable value of services rendered to prevent unjust enrichment. It was undisputed that First Sta. Clara performed works with an estimated value of P4,578,152.10. To deny payment would result in Rivelisa's unjust enrichment. Furthermore, Rivelisa had previously agreed to reimburse First Sta. Clara P3,000,000.00 after the JVA was terminated by mutual assent. Rivelisa could not unilaterally renege on this promise by citing First Sta. Clara's non-fulfillment of the terminated JVA's terms.
Main Doctrine
The 15-day reglementary period for filing a motion for reconsideration before the Court of Appeals is non-extendible. A motion for extension of time to file such motion does not toll the period for the finality of the judgment. Failure to file the proper remedy within the prescribed period renders the decision final and executory.