G.R. No. 131116 - People vs. Sanchez

In December 1992, petitioner B.E. San Diego, Inc. sold an 8,773-square meter parcel of land located in Arkong Bato, Valenzuela City to respondent Manuel A.S. Bernardo on an installment basis.
The total purchase price was set at ₱9,650,300.00, with an initial payment of ₱3,000,000.00 and the balance of ₱6,650,300.00 to be paid over 36 monthly installments of ₱184,730.56 each.

Respondent, however, paid an aggregate amount of only ₱2,054,500.00 and failed to pay the remaining balance as due.
On March 29, 1996, petitioner notified respondent of its intent to cancel the contract and demanded that respondent vacate the subject property.
When respondent did not comply with the demand, petitioner initiated legal proceedings for Cancellation of Contract and Restitution of the Premises, filing Civil Case No. 5088-V-96 before the Regional Trial Court (RTC) of Valenzuela City.

On August 13, 2010, the RTC dismissed petitioner’s complaint, reasoning that petitioner failed to provide respondent with a 60-day grace period under the Maceda Law for paying the installment due.
Petitioner then filed a Motion for Reconsideration on October 4, 2010 through a new collaborating counsel (Ramirez Lazaro & Associates Law Office) without an accompanying Notice of Hearing.
On October 15, 2010, the new counsel subsequently sent a Notice of Hearing via registered mail, purporting that the hearing was set for October 29, 2010.
The RTC, on December 10, 2010, denied the Motion for Reconsideration based on the discovery that the Notice of Hearing was antedated and that its filing was a scheme to meet procedural deadlines, thereby rendering it a “mere scrap of paper.”

Petitioner filed a Notice of Appeal; however, the RTC, by Order dated February 11, 2011, dismissed the appeal for being filed beyond the reglementary period, which rendered the August 13, 2010 Decision final.
On September 6, 2011, petitioner filed a Petition for Relief (Civil Case No. 19-V-12), asserting that the gross negligence of its new collaborating counsel should not bind or prejudice the petitioner.
After trial on the merits, the RTC issued a Decision on October 20, 2014 denying the Petition for Relief and, on July 30, 2015, denied petitioner’s subsequent Motion for Reconsideration.
Petitioner then elevated the matter to the Court of Appeals (CA) by filing a petition for certiorari, leading to a CA Decision on April 3, 2017, which affirmed the RTC’s denial, and a subsequent CA Resolution on July 17, 2017, denying petitioner’s motion for reconsideration.

Whether the neglect and procedural missteps by petitioner’s new collaborating counsel, specifically the failure to timely file a proper Notice of Hearing and the subsequent antedating, should bind the petitioner and result in the loss of its right to appeal.
Whether the established rule that the mistakes of counsel bind the client should be strictly applied or relaxed in cases where the negligence is gross enough to violate the client’s due process and property rights.
Whether a liberal construction of procedural rules, particularly those concerning the filing of the Notice of Hearing, is warranted to prevent a manifest injustice arising from technicalities.