Facts:

The case involves the Subic Bay Metropolitan Authority (SBMA) as the petitioner and Subic Bay Marine Exploratorium, Inc. (SBMEI) as the respondent. The events leading to the case began when SBMA, established under Republic Act No. 7227, sought to impose a Common User Service Area (CUSA) Fee on its direct tenants to recoup expenses incurred for municipal services such as security, fire protection, and street cleaning within the Subic Bay Freeport Zone (SBFZ). On April 13, 2012, SBMA's Board of Directors approved the CUSA fee through Board Resolution No. 12-04-4348, followed by public hearings and subsequent amendments to the resolution. The CUSA fee was communicated to all lessees, including SBMEI, which filed a complaint on December 18, 2012, seeking to declare the CUSA fee illegal and unconstitutional. SBMA responded by asserting that SBMEI failed to exhaust administrative remedies and that the CUSA fee was lawful under its governing laws.

On January 5, 2015, the Regi...

Facts:

1. Creation and Mandate of SBMA:

   • The Subic Bay Metropolitan Authority (SBMA) was created under Republic Act (R.A.) No. 7227 to oversee the development and conversion of the Subic Special Economic Zone (SBFZ). SBMA was tasked with developing the SBFZ as a self-sustaining industrial, commercial, and investment center, generating employment opportunities without financial assistance from the national government.

2. Imposition of CUSA Fee:

   • To recoup expenses for municipal services (security, fire protection, street cleaning, and lighting), SBMA imposed a Common User Service Area (CUSA) Fee on its direct tenants. The annual cost of these services was P388,000,000.00.
   • On April 13, 2012, SBMA approved the CUSA Fee Policy through Board Resolution No. 12-04-4348. Public hearings were conducted, and the policy was published and registered.

3. Legal Challenges:

   • On December 18, 2012, Subic Bay Marine Exploratorium, Inc. (SBMEI), a locator and lessee in SBFZ, filed a complaint challenging the CUSA Fee as illegal and unconstitutional. SBMEI sought to nullify the fee and enjoin its collection.

4. RTC Decision:

   • On January 5, 2015, the Regional Trial Court (RTC) ruled in favor of SBMEI, annulling the CUSA Fee as applied to SBMEI and permanently enjoining SBMA from collecting it.

5. Procedural Missteps:

   • SBMA filed a Motion for Reconsideration, which was denied on August 26, 2015. The RTC Order was received by SBMA’s Legal Department on September 3, 2015, but due to a clerical error, the Notice of Appeal was filed one day late on September 18, 2015. The RTC denied the appeal for being untimely.

6. CA Decision:

   • The Court of Appeals (CA) affirmed the RTC’s denial of SBMA’s appeal, ruling that the RTC did not commit grave abuse of discretion in strictly applying the reglementary period for filing appeals.

Issue:

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Ruling:

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Ratio:

1. Substantial Justice Over Technicalities:

   • The Court reiterated that procedural rules are not absolute and must be relaxed when substantial justice and equity demand. The goal is to afford parties the amplest opportunity for a just determination of their cause, free from technical constraints.

2. Negligence of Counsel and Clerical Errors:

   • While the negligence of SBMA’s legal department and clerk caused the delay, the Court held that such negligence should not prejudice SBMA, especially given the substantial governmental interest involved. The State should not be estopped by the negligence of its agents.

3. Public Interest and Merits of the Case:

   • The CUSA Fee involves significant public interest, as it funds essential municipal services in the SBFZ. Invalidating the fee would result in substantial financial losses for SBMA and the national government. The Court also noted that the CUSA Fee had been upheld in other cases, such as Philip Morris v. SBMA.

4. Equity and Precedent:

   • The Court cited precedents where delays in filing appeals were excused in the interest of justice. In this case, the one-day delay was deemed inconsequential compared to the potential injustice of denying SBMA’s appeal.

5. Judicial Notice of Related Cases:

   • The Court took judicial notice of its prior ruling in Philip Morris v. SBMA, which upheld the validity of the CUSA Fee. Denying SBMA’s appeal would create an absurd situation where SBMEI benefits from municipal services without contributing to their cost.

Conclusion:

The Supreme Court ruled in favor of SBMA, allowing its appeal to proceed despite the one-day delay. The Court emphasized that procedural rules must serve the ends of justice and not hinder it. The case was remanded to the Court of Appeals for a review of the merits of SBMA’s appeal.