Facts:

• The case involves the Subic Bay Metropolitan Authority (SBMA) and Subic Bay Marine Exploratorium, Inc. (SBMEI).
• SBMA imposed a Common User Service Area (CUSA) fee on tenants to fund essential municipal services in the Subic Special Economic Zone (SBFZ).
• SBMA was established under Republic Act No. 7227 to manage the SBFZ.
• On April 13, 2012, SBMA formalized the CUSA fee through Board Resolution No. 12-04-4348 after public hearings.
• The fee aimed to cover annual costs of approximately PHP 388 million for services like security, fire protection, street cleaning, and street lighting.
• On December 18, 2012, SBMEI filed a complaint against SBMA, claiming the CUSA fee was illegal and unconstitutional.
• The Regional Trial Court (RTC) ruled in favor of SBMEI on January 5, 2015, preventing SBMA from collecting the fee.
• SBMA's notice of appeal was filed one day late, leading the RTC to deny the appeal.
• The Court of Appeals (CA) affirmed the RTC's decision, prompting SBMA to seek a review from the Supreme Court.

Issue:

• (Unlock)

Ruling:

• The Supreme Court granted SBMA's petition, reversing the lower courts' decisions.
• The Court allowed SBMA's appeal despite the one-day delay, prioritizing substantial justice and equity.
...(Unlock)

Ratio:

• The Supreme Court stated that procedural rules should not be strictly enforced when substantial justice and public interest are involved.
• The one-day delay was attributed to clerical negligence and should not harm SBMA's rights, given the significant governmenta...continue reading