GR 200469; (January, 2018) (Digest)
G.R. No. 200469 , January 15, 2018
Philippine Savings Bank vs. Josephine L. Papa
FACTS
Petitioner Philippine Savings Bank (PSB) filed a collection case against respondent Josephine Papa before the Metropolitan Trial Court (MeTC) for defaulting on a loan evidenced by a promissory note. Papa, in her Answer, claimed her obligation had been extinguished by payments and denied the basis for the claimed interests and damages. During trial, PSB presented only a photocopy of the promissory note, which the MeTC admitted over Papa’s objection. Papa opted not to present evidence and submitted a memorandum. The MeTC ruled for PSB, ordering Papa to pay the principal with reduced interest and attorney’s fees.
Papa appealed to the Regional Trial Court (RTC), which reversed the MeTC. The RTC held PSB failed to prove its cause of action due to its inability to establish the existence and due execution of the promissory note, noting Papa’s Answer did not constitute an admission of the note’s contents. PSB filed a motion for reconsideration, which it served via a private courier. Papa opposed, arguing the motion was filed out of time because service by private courier is not a mode recognized by the Rules of Court for computing timeliness. The RTC denied the motion, declaring its decision had attained finality.
ISSUE
Whether the Court of Appeals correctly affirmed the RTC’s ruling that its decision had attained finality due to PSB’s belated filing of its motion for reconsideration.
RULING
Yes. The Supreme Court affirmed the Court of Appeals. The core issue was procedural finality. Under the Rules of Court, a party has only five days from receipt of an RTC decision in an appealed case to file a motion for reconsideration. Service of such a motion must be done through modes prescribed by the Rules, such as personal service, registered mail, or accredited courier. PSB used a non-accredited private courier service. Jurisprudence consistently holds that service by such means is not considered completed upon deposit with the courier but only upon actual receipt by the party. PSB offered no justification for deviating from the prescribed modes. Consequently, its motion was filed one day late, rendering the RTC decision final and executory.
The Court emphasized that while litigation is not a game of technicalities, adherence to procedural rules is essential for the orderly administration of justice. A decision that has attained finality becomes immutable and unalterable. This principle of immutability of final judgments barred any further review of the substantive merits of the RTC’s ruling on PSB’s failure to prove its cause of action. Therefore, the petition was dismissed for lack of merit.