GR 160753; (September, 2004) (Digest)
G.R. No. 160753 ; September 30, 2004
JIMMY L. BARNES, petitioner, vs. HON. MA. LUISA QUIJANO PADILLA, Presiding Judge, RTC, Branch 215, Quezon City and TERESITA C. REYES, et al., respondents.
FACTS
Private respondents filed an ejectment case against petitioner for non-payment of rentals under a Contract of Lease. The Metropolitan Trial Court (MeTC) ruled in their favor. Petitioner appealed to the Regional Trial Court (RTC, Branch 227), which reversed the MeTC, holding it lacked jurisdiction as the core issue involved the specific performance of a subsequent Memorandum of Agreement (MOA) granting petitioner an option to purchase. While that appeal was pending, petitioner himself filed a separate complaint for specific performance to enforce the MOA before another RTC branch (Branch 215). Private respondents moved to dismiss this second case on the ground of forum-shopping, citing the pending appeal (which involved the MOA’s validity) before the Court of Appeals. Branch 215 dismissed the specific performance case.
Petitioner challenged this dismissal via a petition for certiorari with the Court of Appeals (CA). The CA dismissed his petition, finding he committed forum-shopping. Petitioner received this CA decision on August 26, 2003. On September 3, he filed a motion for a 15-day extension to file a motion for reconsideration. He filed his motion for reconsideration on September 23. The CA denied the extension, citing the non-extendible 15-day period for filing a motion for reconsideration, and subsequently denied admission of the belated motion.
ISSUE
Whether the Court of Appeals correctly denied petitioner’s motion for reconsideration for being filed out of time.
RULING
Yes, the Court of Appeals was correct. The reglementary period for filing a motion for reconsideration in the CA is strictly fifteen (15) days from notice of the decision or final order. This period is non-extendible. The rule is explicit and admits of no exception. Petitioner received the CA decision on August 26, 2003. His period to file a motion for reconsideration expired on September 10, 2003. His filing on September 23 was indisputably late. His prior motion for extension was a mere scrap of paper, as no court can grant an extension for a non-extendible period.
The Supreme Court emphasized that procedural rules are not mere technicalities but are designed to ensure the orderly administration of justice. The principle of finality of judgments is paramount. Allowing extensions for filing motions for reconsideration of CA decisions would indefinitely delay the termination of cases, undermining judicial stability. Petitioner’s failure to comply with this mandatory period rendered the CA decision final and executory. His subsequent petition before the Supreme Court, which assailed the CA’s dismissal, was therefore properly denied, as the assailed CA resolution had already attained finality. The Court found no compelling reason to relax the rules, as petitioner’s own procedural lapses, not a denial of due process, caused his predicament.