GR 194638; (July, 2014) (Digest)
G.R. No. 194638 ; July 2, 2014
PARAÑAQUE KINGS ENTERPRISES, INC., Petitioner, vs. CATALINA L. SANTOS, represented by her Attorney-in-Fact, LUZ B. PROTACIO, and DAVID R. RAYMUNDO, Respondents.
FACTS
Petitioner Parañaque Kings Enterprises, Inc. filed a complaint for breach of contract with damages against respondents Catalina L. Santos and David R. Raymundo before the Regional Trial Court (RTC) of Makati City. The complaint alleged that Santos, as lessor, violated the “first option or priority to buy” clause in a lease contract by selling the leased properties to Raymundo without first offering them to petitioner at the price of ₱9,000,000. The RTC initially dismissed the complaint for lack of cause of action, but the Supreme Court, in a Decision dated February 26, 1997, reversed and remanded the case for trial, finding that the complaint sufficiently alleged an actionable breach.
Upon remand, respondents filed their Answer with Compulsory Counterclaims. Petitioner filed a Motion to Strike Out certain allegations in the Answer, arguing they contradicted the Supreme Court’s factual findings in its February 26, 1997 Decision. The RTC denied the motion. Petitioner then moved for reconsideration and for the voluntary inhibition of the judge, which was also denied. The RTC set the case for pre-trial on July 7, 1998.
On July 2, 1998, petitioner filed a Motion to Cancel Pre-Trial, stating it would file a petition for certiorari and prohibition with the Court of Appeals (CA) before the scheduled pre-trial to challenge the RTC’s orders. The RTC denied the motion in its First Order dated July 7, 1998 and directed the parties to proceed with pre-trial. During the pre-trial, petitioner’s counsel refused to proceed, stating he would furnish the court a copy of the petition the next day. Consequently, the RTC declared petitioner non-suited and dismissed the complaint in its Second Order dated July 7, 1998. Petitioner’s motion for reconsideration was denied.
Petitioner filed a Notice of Appeal, but the RTC denied it due course for being filed out of time, ruling that the motion for reconsideration was pro forma and did not toll the appeal period. Petitioner then filed a petition for certiorari, mandamus, and prohibition with the CA, which was dismissed. The CA subsequently affirmed the RTC’s orders in a Decision dated September 22, 2010, prompting this petition.
ISSUE
Whether the Court of Appeals erred in affirming the RTC’s Orders that: (a) denied petitioner’s Motion to Cancel Pre-Trial; (b) declared petitioner non-suited and dismissed the complaint for refusal to proceed with pre-trial; and (c) denied petitioner’s motion for reconsideration.
RULING
The Supreme Court denied the petition and affirmed the CA’s Decision. The Court held:
1. On the denial of the Motion to Cancel Pre-Trial: The RTC did not commit grave abuse of discretion. The motion was based on petitioner’s intention to file a petition for certiorari, which was not a valid ground to cancel pre-trial. The filing of a special civil action does not automatically suspend proceedings unless a temporary restraining order or writ of preliminary injunction is issued. Petitioner’s petition for certiorari was actually filed on the afternoon of July 7, 1998, after the pre-trial had commenced, contradicting its claim it would be filed before pre-trial.
2. On the dismissal of the complaint for refusal to proceed with pre-trial: The RTC acted within its authority under Section 3, Rule 17 of the Rules of Court, which allows dismissal for failure to comply with court orders. Petitioner’s counsel defiantly refused to proceed with pre-trial despite the RTC’s directive, constituting willful disobedience. The dismissal was not based on the merits but on petitioner’s disregard of the court’s lawful order.
3. On the denial of the motion for reconsideration: The RTC correctly ruled that the motion for reconsideration was pro forma as it failed to point out specific errors in the July 7, 1998 Orders and merely reiterated previous arguments. Being pro forma, it did not toll the period to appeal, rendering the Notice of Appeal filed on September 30, 1998 out of time.
The Supreme Court emphasized that procedural rules are designed to ensure orderly administration of justice, and petitioner’s disregard of these rules warranted the dismissal of its complaint. The CA committed no reversible error in affirming the RTC’s orders.