GR 152801; (August, 2004) (Digest)
G.R. No. 152801 ; August 20, 2004
COSMO ENTERTAINMENT MANAGEMENT, INC., petitioner, vs. LA VILLE COMMERCIAL CORPORATION, respondent.
FACTS
The respondent, La Ville Commercial Corporation, leased a property to petitioner Cosmo Entertainment Management, Inc. The petitioner defaulted on rental payments starting September 1996. After failed negotiations, the respondent filed an unlawful detainer case. The Metropolitan Trial Court (MeTC) ruled for the respondent, ordering the petitioner to vacate and pay accrued rentals. The Regional Trial Court (RTC) affirmed this decision in toto on June 26, 2000.
The petitioner received the RTC decision on July 6, 2000. On the last day to appeal, July 21, 2000, it filed a Motion for Extension with the Court of Appeals (CA). The CA granted a non-extendible 15-day extension, until August 5, 2000. Disregarding this, the petitioner filed a second motion for extension on August 4, 2000, and eventually filed its Petition for Review on August 18, 2000. The CA dismissed the petition for being filed out of time.
ISSUE
Whether the Court of Appeals correctly dismissed the petition for review for having been filed beyond the reglementary period.
RULING
Yes, the Court of Appeals correctly dismissed the petition. The Supreme Court affirmed the CA’s resolutions. Procedural rules on reglementary periods for appeal are mandatory and jurisdictional. The petitioner received the RTC decision on July 6, 2000, making the last day to file a petition for review July 21, 2000. The CA’s initial resolution explicitly granted a “non-extendible” 15-day extension until August 5, 2000. The filing of a second motion for extension was a prohibited pleading, and the subsequent petition filed on August 18, 2000 was indisputably late.
The legal logic is grounded in the principle that adherence to procedural rules is essential for the orderly administration of justice. While the Court may exercise liberality in meritorious cases, such discretion is not warranted here. The petitioner offered no compelling reason for its failure to comply, and its claim of a “novel issue” regarding the sublease provision was unavailing, as the substantive findings of the lower courts were sound. The contract expressly required the lessor’s consent for any sublease, a valid stipulation under the principle of mutuality of contracts. The petitioner’s failure to pay rent constituted a clear breach, justifying rescission and ejectment. The Supreme Court found no reason to disturb these factual conclusions. Thus, the dismissal for tardiness was proper.