G.R. No. 189618 ; January 15, 2014
RIVELISA REALTY, INC., represented by RICARDO P. VENTURINA, Petitioner, vs. FIRST STA. CLARA BUILDERS CORPORATION, represented by RAMON A. PANGILINAN, as President, Respondent.

FACTS

Petitioner Rivelisa Realty and respondent First Sta. Clara entered into a Joint Venture Agreement (JVA) for a subdivision development project. Under the JVA, First Sta. Clara was to fund and complete the horizontal development of the remaining 69% of the project within twelve months. First Sta. Clara commenced work but ceased operations after two months due to lack of funds. In a letter dated August 24, 1995, Rivelisa Realty agreed to release First Sta. Clara from the JVA. Subsequent correspondence involved negotiations over the valuation of First Sta. Clara’s accomplished works, culminating in Rivelisa Realty’s October 9, 1995 letter agreeing to reimburse the amount of Three Million Pesos (P3,000,000.00). First Sta. Clara later filed a complaint for rescission and damages after Rivelisa failed to pay. The Regional Trial Court (RTC) dismissed the complaint, finding First Sta. Clara in breach for failing to fulfill its initial funding obligation.
The Court of Appeals (CA) reversed the RTC, holding Rivelisa Realty liable for the P3,000,000.00 reimbursement. Rivelisa received the CA Decision on March 3, 2009. On March 18, 2009, the last day of the 15-day reglementary period, it filed a motion for a 15-day extension to file a motion for reconsideration. It filed the actual motion for reconsideration on April 2, 2009. The CA denied the motion for extension, noting the motion for reconsideration was filed out of time, as the period is non-extendible.

ISSUE

The issues are whether the CA erred in: (1) ruling the 15-day period to file a motion for reconsideration is non-extendible; and (2) finding First Sta. Clara entitled to compensation for accomplished works.

RULING

The Supreme Court denied the petition. On the procedural issue, the Court affirmed that the 15-day period for filing a motion for reconsideration of a CA decision is indeed non-extendible. This rule is explicitly provided under Section 2, Rule 52 of the Rules of Court. The Court cited precedents like Habaluyas Enterprises, Inc. v. Japson and Aguam v. CA, which firmly establish this doctrine to ensure the orderly and speedy disposition of cases. Rivelisa’s motion for extension filed on the last day was thus correctly denied, rendering its subsequent motion for reconsideration a mere scrap of paper.
On the substantive issue, the Court upheld the CA’s finding that Rivelisa Realty is liable to pay. The JVA was terminated by mutual consent through the exchange of correspondence. Rivelisa’s letter agreeing to release First Sta. Clara effectively dissolved the original contractual obligations. However, a new obligation arose from Rivelisa’s subsequent agreement, expressed in its October 9, 1995 letter, to pay the P3,000,000.00 reimbursement for work accomplished. This separate agreement, founded on the principle of solutio indebiti or quasi-contract, is binding. Rivelisa cannot evade this self-imposed obligation by reverting to the unfulfilled conditions of the already-terminated JVA. The claim is based on its own voluntary commitment, not on the breached JVA.