GR 164150; (April, 2008) (Digest)
G.R. No. 164150 ; April 14, 2008
THE GOVERNMENT OF THE KINGDOM OF BELGIUM, represented by the Royal Embassy of Belgium, petitioner, vs. HON. COURT OF APPEALS, UNIFIED FIELD CORPORATION, MARILYN G. ONG, VICTORIA O. ANG, EDNA C. ALFUERTE, MARK DENNIS O. ANG and ALVIN O. ANG, respondents.
FACTS
Petitioner Government of the Kingdom of Belgium leased property from respondent Unified Field Corporation (UFC). The lease contract contained a pre-termination clause. Petitioner validly pre-terminated the lease after the second year, vacated the premises, and demanded the return of its unused advance rentals and security deposit totaling P1,093,600.00. Respondents failed to return the amount. Petitioner filed a complaint for specific performance with damages. The Regional Trial Court (RTC) ruled in favor of petitioner after respondents were declared to have waived their right to present evidence for failure to appear at pre-trial and file a pre-trial brief. The RTC awarded the principal sum, damages, and attorney’s fees.
Respondents appealed to the Court of Appeals but failed to file their appellant’s brief within the extended period. Petitioner moved to dismiss the appeal. The Court of Appeals initially granted the dismissal but later reversed itself via a Resolution dated November 27, 2003, granting respondents’ motion for reconsideration and admitting the late-filed brief. The appellate court cited “the interest of justice” and the “transcendental importance” of holding corporate directors liable under Section 31 of the Corporation Code. Petitioner’s motion for reconsideration was denied.
ISSUE
Whether the Court of Appeals committed grave abuse of discretion in granting respondents’ motion for reconsideration and admitting their late-filed appellant’s brief.
RULING
Yes. The Court of Appeals committed grave abuse of discretion. The grant of the motion for reconsideration was a patent and gross violation of procedural rules, amounting to an evasion of a positive duty. Procedural rules are not to be belittled or dismissed simply because their non-observance may result in prejudice to a party’s substantive rights. Adherence to the reglementary periods is mandatory and imperative.
The appellate court’s reliance on “the interest of substantial justice” and the “transcendental importance” of the issue of director liability was misplaced. The case involved a simple collection of a sum of money based on a contract of lease. The matter of holding directors solidarily liable, while significant, is not of such transcendental importance as to excuse blatant procedural defaults. Respondents exhibited a clear pattern of disregard for court processes, from their failure to attend pre-trial to their failure to file their brief on time. Litigation is not a game of technicalities, but it is equally true that every case must be prosecuted in accordance with the prescribed procedure to ensure an orderly and speedy administration of justice. The Court of Appeals’ decision to relax the rules under these circumstances was whimsical and capricious, constituting grave abuse of discretion. The resolutions of the Court of Appeals were annulled and set aside, and the appeal of respondents was dismissed.