GR 175163; (October, 2007) (Digest)
G.R. No. 175163 ; October 19, 2007
LAND BANK OF THE PHILIPPINES, Petitioner, vs. ASCOT HOLDINGS AND EQUITIES, INC., CUBE FACTOR HOLDINGS, INC., SIERRA HOLDINGS & EQUITIES, INC. AND POL HOLDINGS, INC., Respondents.
FACTS
Petitioner Land Bank of the Philippines (Land Bank) was a stockholder of Philippine Airlines (PAL). Respondents, along with other government financial institutions, were parties to a Stockholders’ Agreement executed in 2002. Under this agreement, Land Bank and other government entities had a put option, allowing them to sell their PAL shares to respondents at ₱5.00 per share on the sixth year. The obligation of respondents to buy was guaranteed jointly and severally by Asia Brewery Inc. and Fortune Tobacco Corporation. Instead of honoring this agreement, respondents filed a complaint with the Makati RTC (Civil Case No. 02-843) seeking release from their obligation under the doctrine of rebus sic stantibus, citing unforeseen events like PAL’s financial troubles and economic downturns.
The RTC ruled in favor of respondents. Land Bank sought to appeal this judgment to the Court of Appeals via a petition for review under Rule 43. However, Land Bank filed a motion for extension of time to file the petition. The CA denied this motion for extension and subsequently denied Land Bank’s motion for reconsideration. The CA held that the reglementary period for filing a Rule 43 petition is non-extendible. Land Bank then filed the instant petition for certiorari and mandamus before the Supreme Court.
ISSUE
Whether the Court of Appeals committed grave abuse of discretion in denying Land Bank’s motion for extension of time to file a petition for review under Rule 43.
RULING
No, the Court of Appeals did not commit grave abuse of discretion. The Supreme Court affirmed the CA’s dismissal. The legal logic is firmly rooted in procedural rules and the principle of finality of judgments. The period for filing a petition for review under Rule 43 of the Rules of Court is fixed at fifteen (15) days from notice of the judgment. This period is jurisdictional and non-extendible. The Court has consistently ruled that a motion for extension of time to file such a petition is a prohibited pleading.
Land Bank’s failure to file within the reglementary period rendered the RTC decision final and executory. The Court emphasized that procedural rules prescribing time limits are indispensable to prevent needless delays and ensure the orderly and speedy discharge of judicial business. These rules may be relaxed only in exceptionally meritorious cases. The Court found Land Bank’s situation not meritorious enough to warrant relaxation. Its claim of potentially losing a substantial investment was deemed more speculative than real, as it continued to hold the PAL shares and would benefit from any corporate success. Since no grave abuse of discretion by the CA was found, the petition was dismissed.