G.R. No. 189618 - Rivelisa Realty, Inc. vs. 1st Sta. Clara Builders Corp.

On January 25, 1995, Rivelisa Realty, Inc. (Rivelisa Realty) and First Sta. Clara Builders Corporation (First Sta. Clara) entered into a Joint Venture Agreement (JVA) for the construction and development of a residential subdivision in Cabanatuan City.
Under the JVA terms, First Sta. Clara was tasked to undertake horizontal development of the remaining 69% undeveloped portion of the project, with a completion period of twelve (12) months from signing.
Upon completion, 60% of the subdivided lots would be transferred to First Sta. Clara.
Since 31% of the project had been developed previously by Rivelisa Realty with an assessed value of ₱10,000,000.00, First Sta. Clara was to initially expend the equivalent amount before claiming funds from pre-sale of the initially developed lots.
Additional works not included originally in the JVA were to be borne 40% by Rivelisa Realty and 60% by First Sta. Clara.

First Sta. Clara hired a subcontractor for horizontal development, including riprap and road embankment elevation.
After two months, First Sta. Clara ran out of funds, forcing Rivelisa Realty to advance part of the subcontractor’s payments.
First Sta. Clara expressed intention to withdraw from the JVA when Rivelisa Realty refused to provide further funding until at least 60% of the project was completed.
Rivelisa Realty, in a letter dated August 24, 1995, agreed to release First Sta. Clara from the JVA, estimating actual accomplishment at ₱4,000,000.00, including subcontractor payments and cash advances.
First Sta. Clara claimed a higher valuation of accomplished works at ₱4,578,142.10 and sought reimbursement of ₱3,000,000.00 after deducting cash advances and subcontractor fees.
After correspondence, Rivelisa Realty agreed to reimburse ₱3,000,000.00, emphasizing this amount was beyond its contractual obligations under the JVA.
Payment was not made despite demands, prompting First Sta. Clara to file a complaint for rescission of the JVA alleging breach of contract and damages due to delay.

The RTC ruled in favor of Rivelisa Realty, dismissing First Sta. Clara’s complaint and ordering First Sta. Clara to pay Rivelisa Realty damages and attorney’s fees for counterclaims.
The RTC found that First Sta. Clara failed to meet essential conditions of the JVA, including completing the development within 12 months, spending the initial ₱10,000,000.00, and accomplishing 60% of the work.
Since First Sta. Clara ceased work prematurely due to lack of funds, it was the party who first violated the agreement.

On appeal, the CA reversed the RTC, finding Rivelisa Realty liable to compensate First Sta. Clara for actual work done amounting to ₱3,000,000.00 after deducting advances and costs.
The CA held that the JVA was terminated by mutual assent, freeing First Sta. Clara from further obligations.
Rivelisa Realty filed a motion for extension of time to file a motion for reconsideration beyond the 15-day reglementary period.
The CA denied the motion for extension and subsequently denied the motion for reconsideration as late-filed.

Rivelisa Realty filed a petition for review on certiorari questioning the non-extendible time for filing a motion for reconsideration and the entitlement of First Sta. Clara to compensation for the completed works.

Whether the Court of Appeals erred in ruling that the 15-day reglementary period for filing a motion for reconsideration is non-extendible.
Whether First Sta. Clara is entitled to compensation for the development works performed on the project despite the termination of the Joint Venture Agreement.