G.R. No. 164668 - Asian Spirit Airlines vs. Spouses Bautista

The case involves Asian Spirit Airlines (Airline Employees Cooperative) as the petitioner and the Bautistas (Spouses Benjamin and Anne Marie Bautista, Karl Bautista, and Gloria Pomera) as the respondents.
The origin of the dispute is a complaint filed by the spouses on behalf of their son and Gloria Pomera for breach of contract and damages against the airline in the Regional Trial Court of Pasig City.

After trial, the Regional Trial Court rendered a decision on March 24, 2003 in favor of the plaintiffs (the Bautistas) awarding:

Following the denial of its motion for reconsideration by the trial court, the defendant (Asian Spirit Airlines) appealed.
The appeal was docketed as CA-G.R. CV No. 79317 with the Court of Appeals.
The appellate court directed the petitioner to file its briefs within 45 days following notice, with the period ending on January 31, 2004; however, the petitioner failed to file the brief within the prescribed deadline.

On March 3, 2004, the respondents filed a Manifestation and Motion to dismiss the appeal for the petitioner’s failure to file its brief.
On March 10, 2004, the petitioner filed an unverified Motion to Admit Attached Appellantas Brief, which was opposed by the respondents.
On April 23, 2004, the Court of Appeals issued a resolution denying the petitioner’s motion and granting the respondents’ motion for dismissal of the appeal.
A subsequent motion for reconsideration by the petitioner was denied on July 16, 2004, based on a lack of merit.

The petitioner elevated the case to the Supreme Court through a petition for review on certiorari, challenging the CA’s decision and arguing:

That the Court of Appeals strictly applied the Rules of Court without considering the mandated precept of liberal construction.
That the petitioner's appeal was based on meritorious grounds where denying it would prejudice its substantial rights and due process.

The petitioner contended that the late filing did not cause material injury or prejudice and that issues raised in its brief warranted an examination of the evidence on record.

The CA acted within its discretion by admonishing the petitioner for failing to file its brief on time.
The petitioner’s excuse—that its counsel instructed the secretary to file the motion for extension and that the secretary forgot—is unacceptable and indicative of negligence.

They stressed the importance of strict adherence to procedural deadlines to ensure orderly administration of justice, citing established jurisprudence (e.g., Don Lino Gutierrez & Sons, Inc. vs. CA).

The Supreme Court ruled that the petitioner’s failure to file its brief within the allowed period resulted in a forfeiture of its right to appeal.
The petition was denied for lack of merit with costs imposed against the petitioner.

Whether the Court of Appeals erred in dismissing the petitioner's appeal solely on the ground of its failure to file the brief within the prescribed period.
Whether the petitioner’s explanation—that its counsel’s secretary failed to file the necessary motion for extension—constitutes a valid and persuasive ground to excuse the procedural lapse.
Whether strict compliance with the procedural requirements, as mandated by the Rules of Court, should be relaxed in cases where the alleged negligence does not cause material prejudice to the opposing party.