G.R. No. 242900 - Saulo vs. People

Petitioner, the Government of the Kingdom of Belgium (represented by the Royal Embassy of Belgium), initiated a Complaint for specific performance of contract with damages against respondents, which include Unified Field Corporation (UFC) and its principal officers.
A Contract of Lease was executed on 30 July 1997 between petitioner and UFC, represented by its President and co-respondent, Marilyn G. Ong.
Under the contract, petitioner leased Units “B” and “D” at the Chatham House Condominium in Makati City, covering a gross area of approximately 377 square meters along with six parking lots, for a maximum term of four years commencing on 1 October 1997.
The agreed rental payments included a gross sum for the first two years along with a security deposit, totaling P6,109,020.00.

The lease contract provided for a pre-termination option exercisable by the lessee after the expiry of the second-year term without the imposition of pre-termination penalties.
On or about 23 June 2000, petitioner served a letter to respondent UFC (through its President Marilyn G. Ong) informing its intention to pre-terminate the lease effective 31 July 2000.
Petitioner simultaneously demanded the refund or return of P1,093,600.00, which comprised two months’ worth of advance rental (P414,820.00) and the security deposit (P678,780.00), to be remitted within forty-five days after vacating the premises.
On 31 July 2000, petitioner vacated and surrendered the leased premises, having settled all utility obligations and incurred no damages as certified by the corresponding documents.

The complaint was filed with the Regional Trial Court (RTC) of Makati City, Branch 150, filed as Civil Case No. 01-976.
Respondents failed to appear at pre-trial and did not file a pre-trial brief, thereby waiving their right to present evidence.
Petitioner was allowed to present evidence ex parte, resulting in the RTC’s decision rendered on 8 November 2002, which ordered the respondents, jointly and severally, to pay the refund along with interest and additional damages (attorney's fees, litigation expenses, moral and exemplary damages), as well as the costs of suit.

Respondents elevated the case on appeal, receiving a Notice to File Brief from the Court of Appeals.
Respondents failed to file their appellant’s brief within the reglementary period, prompting petitioner to move for the dismissal of their appeal on the basis of this technical default.
On 30 September 2003, the Court of Appeals issued a Resolution dismissing the appeal pursuant to Section 1(e), Rule 50 of the Rules on Civil Procedure.
Respondents later filed a Motion for Reconsideration on 27 October 2003, alleging that their failure was due to the inadvertence of counsel (attributed to a misdirected mailing address and administrative oversight).
On 27 November 2003, the Court of Appeals granted the motion, reversed its earlier dismissal, and allowed the late filing of the appellant’s brief.
Petitioner then filed a Motion for Reconsideration of the November 27, 2003 Resolution, which was denied by the Court of Appeals in its Resolution dated 5 May 2004.

Petitioner asserts that the respondents’ failure to observe the prescribed reglementary period for filing the brief is a clear violation of the Rules of Court and that the alleged inadvertence is an unpersuasive excuse.
Respondents contend that the substantial merits of the appeal outweigh the procedural infirmity and argue that rigid application of technical rules would hinder the proper adjudication of their case.
The issue raises questions on whether administrative lapses and counsel’s negligence can justify a relaxation of procedural timelines in view of substantial justice and public interest.

Whether the respondents’ failure to file the appellant’s brief within the prescribed 45-day reglementary period constitutes a sufficient ground to dismiss their appeal.
Whether an alleged inadvertence on the part of respondents’ counsel justifies the relaxation of procedural rules in the interest of substantial justice.
Whether the actions of the Court of Appeals—first dismissing the appeal and subsequently reversing that decision and then denying petitioner’s motion for reconsideration—amount to grave abuse of discretion or a manifestation of proper judicial discretion under the Rules of Court.