Case Digest (G.R. No. 160753)
Facts:
Jimmy L. Barnes v. Hon. Ma. Luisa Quijano Padilla, et al., G.R. No. 160753, September 30, 2004, Supreme Court Second Division, Austria‑Martinez, J., writing for the Court.
On April 29, 1998, private respondents (Teresa C. Reyes, Elizabeth C. Pasion, Ma. Elsa C. Garcia, Imelda C. Trillo, Ma. Elena C. Dinglasan and Ricardo P. Crisostomo) filed an ejectment complaint in the Metropolitan Trial Court (MeTC), Branch 34, Quezon City against petitioner Jimmy L. Barnes for alleged nonpayment of rent under a lease covering a property at 114 West Ave., Quezon City (Civil Case No. 19992). On October 26, 1998, the MeTC found Barnes liable and ordered him to vacate the premises. Barnes appealed to the Regional Trial Court (RTC), Branch 227, Quezon City (Civil Case No. Q‑99‑36479), contending lack of jurisdiction and cause of action.
While the appeal was pending, Barnes filed on March 27, 1999 a separate complaint for specific performance with damages in RTC Branch 215 (Civil Case No. Q‑99‑37219), seeking enforcement of a December 5, 1995 Memorandum of Agreement (MOA) that, he alleged, extended the lease and provided an option to purchase a portion of the property. On May 5, 1999 Branch 227 ruled the MeTC lacked jurisdiction and set aside the MeTC decision, dismissing the ejectment case without prejudice. Private respondents' motion for reconsideration in Branch 227 was denied and they brought a petition for review to the Court of Appeals (CA) (CA‑G.R. SP No. 55949), which remained pending.
During trial in Branch 215, private respondents moved to dismiss Barnes' specific performance complaint for forum‑shopping because of the pending CA appeal involving the earlier ejectment matter. On April 20, 2001 Branch 215 dismissed the specific performance complaint; its December 21, 2001 resolution denying reconsideration was later affirmed by the CA in CA‑G.R. SP No. 69573 by decision dated August 18, 2003 (which Barnes received on August 26, 2003). Barnes sought to file a motion for reconsideration in the CA: he filed a Motion for Extension on September 3, 2003, filed a motion for reconsideration on September 23, 2003, and the CA denied the extension (Sep. 25, 2003) and later denied admission of the motion for reconsideration (Resolution dated November 17, 2003) on the ground that it was filed beyond the fifteen‑day reglementary period.
Barnes filed a petition for review on certiorari under Rule 45 with the Supreme Court on December 22, 2003, after an initial denial of an extension to file the petition; this Court initially denied an extension for lack of material dates but later, a...(Pro-only)
Issues:
- Whether the Court of Appeals gravely abused its discretion in denying petitioner's manifestation and motion to admit his motion for reconsideration on the ground that the motion was filed beyond the fifteen‑day reglementary period (procedural timeliness and effect of a motion for extension).
- Whether petitioner committed forum‑shopping such that the RTC Branch 215 correctly dismissed his complaint for specific performance (substantive question of forum‑shopping).
- Whether the Supreme Court should nevertheless relax finality rules and entertain the petition des...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)