Yap-Sumndad v. Friday's Holdings, Inc.
REITERATIONFacts
The Antecedents: This case originated from a forcible entry complaint filed by Friday's Holdings, Inc. (respondent) against Spouses Mila Yap-Sumndad and Atty. Daligdig Sumndad, Datu Yap Sumndad, Joel Gelito, and John Does (petitioners). The respondent sought to be declared the actual prior possessor and owner of the subject property, praying for continuous, exclusive, peaceful, and actual possession thereof. Procedural History: The Municipal Circuit Trial Court (MCTC) ruled in favor of the respondent, ordering the petitioners to restore possession and pay compensation for use and occupation, along with attorney's fees. On appeal, the Regional Trial Court (RTC) affirmed the MCTC's decision but modified the compensation for lost profits to P74,480,000.00. The petitioners then filed a Petition for Review with the Court of Appeals (CA). The CA dismissed this petition on May 15, 2017. A subsequent Motion for Reconsideration filed by the petitioners was denied by the CA on October 30, 2017. The Petition: The petitioners are before the Supreme Court via a Petition for Review on Certiorari, assailing the CA's Resolution dated October 30, 2017, which denied their Motion for Reconsideration. The core issue presented is whether the CA erred in denying the motion for being belatedly filed. The petitioners argue that while their counsel's office received the CA Resolution on May 29, 2017, it was only brought to the handling counsel's attention on June 19, 2017, due to an inadvertent oversight by a secretary. They sought leniency, emphasizing substantial justice over technicalities. However, the CA found the motion was filed 20 days beyond the 15-day reglementary period, rendering the CA Resolution of May 15, 2017 final and executory.
Issue(s)
Whether the Court of Appeals erred in denying the petitioners' Motion for Reconsideration for belated filing. Whether the petitioners' belated filing of the Motion for Reconsideration can be excused on the ground of substantial justice.
Ruling
The Supreme Court denied the petition and affirmed the Resolutions of the Court of Appeals dated May 15, 2017, and October 30, 2017. The Court held that the petitioners' Motion for Reconsideration was filed 20 days beyond the fifteen-day reglementary period, rendering the CA Resolution final and executory.
Ratio Decidendi
On the issue of belated filing of the Motion for Reconsideration: The Court held that the petitioners' Motion for Reconsideration was filed beyond the fifteen (15)-day reglementary period provided by Section 1, Rule 52 of the Rules of Court. The petitioners' counsel received the CA Resolution on May 29, 2017, making the deadline for filing the motion June 13, 2017. However, the motion was only filed on July 3, 2017. The Court emphasized that if a motion for reconsideration is filed beyond the period to appeal, it ipso facto forecloses the right to appeal. The Court reiterated that the negligence of a secretary or clerk in filing a pleading is imputable to the counsel. The Court stressed that the relaxation of procedural rules must remain an exception, not a general rule, and should not be used by litigants to violate rules with impunity. The Court cited previous rulings where motions filed even one day late were refused admission without sufficient justification. Therefore, the CA did not err in denying the motion for being belatedly filed. On the issue of substantial justice: The Court ruled that invoking substantial justice does not automatically compel the Court to suspend procedural rules. Procedural rules cannot simply be set aside on the basis that their non-observance may have prejudiced a party's substantive rights. The Court clarified that the relaxation of rules in exceptional cases was never intended to provide a sanctuary for erring litigants to violate rules with impunity. The petitioners' admission of fault and their plea for leniency due to inadvertence were not considered sufficient grounds to deviate from the strict application of the Rules of Court, especially when the filing was significantly beyond the reglementary period. The Court maintained that adherence to procedural rules is essential for the orderly administration of justice.
Main Doctrine
A motion for reconsideration filed beyond the fifteen (15)-day reglementary period, even if filed within the same calendar month, is considered belated and forecloses the right to appeal, unless there are exceptionally meritorious circumstances justifying a liberal application of the rules, which were not sufficiently demonstrated in this case.