Title
Ram's Studio and Photographic Equipment, Inc. vs. Court of Appeals
Case
G.R. No. 134888
Decision Date
Dec 1, 2000
RAM'S failed to timely file a motion for new trial after breaching a wedding videography contract, rendering the judgment final and executory.
damages
wedding
video tape

Case Summary (G.R. No. 134888)

Factual Background

On 8 November 1994, private respondent Gina Cynthia Hernal contracted RAM’S to provide video coverage of the wedding ceremony and reception of the private respondents. The wedding rites were scheduled for 6:00 o’clock p.m. on 27 January 1995. However, when the bride was still at her hotel room as of a quarter past 5:00 o’clock p.m., the videographers of RAM’S allegedly failed to arrive on time. Because of the delay, private respondent was able to proceed to the altar only at 7:00 o’clock p.m.. Further, the private respondents claimed that the videotape delivered not long after was damaged. When they and their families viewed the tape, they allegedly observed that for the first thirty-minute play there was only a brownish-black screen with silhouettes that appeared to be people.

RAM’S, through Mrs. Daffon, offered to retake the damaged portion free of charge and to shoulder incidental expenses such as make-up. Private respondents rejected the offer. On 5 July 1995, private respondents instituted a complaint for damages before the RTC of Muntinlupa City.

Complaint, Amended Pleading, and Default

Private respondents filed an initial complaint, and on 23 August 1995 they amended it prior to the filing of any responsive pleading to the original complaint. RAM’S twice sought extension of time to answer, but it failed to file an answer within the extended period. Consequently, on 22 January 1996, the trial court declared RAM’S in default. After private respondents presented their evidence ex parte, the RTC rendered a decision awarding actual, moral, and exemplary damages, attorney’s fees, and costs.

RTC Decision and Petitioner's Belated Motion for New Trial

The RTC decision’s dispositive portion ordered RAM’S to pay: P5,950.00 as actual damages, P500,000.00 as moral damages, P500,000.00 as exemplary damages, P100,000.00 plus P2,000.00 per appearance for attorney’s fees, and costs of suit. On 10 April 1996, counsel for RAM’S received a copy of the RTC decision. Petitioner filed a Motion for New Trial on 26 April 1996, which the RTC treated as filed one day after the fifteen-day reglementary period. Private respondents then moved for issuance of a writ of execution and opposed the belated motion.

On 11 October 1996, the RTC granted the motion for execution. On 13 January 1997, it denied petitioner’s motion for reconsideration. In line with those rulings, the RTC issued a writ of execution on 14 January 1997. Yet, by an order dated 6 March 1997, the RTC reversed course and granted petitioner’s motion for new trial. The RTC reasoned that the decision had been received by Atty. Orlando Alcaraz on April 10, 1996, but the decision served upon RAM’S itself occurred on April 11, 1996; hence, counted from the receipt by the defendant itself, the motion for new trial was timely. It also found that even counting from Atty. Alcaraz’s receipt, the motion—though one day late—was still within the period to seek relief under Rule 38, Section 2.

Private Respondents’ Appeal to the Court of Appeals

On 24 June 1997, private respondents’ motion for reconsideration was denied, prompting them to elevate the matter. The RTC’s orders dated 6 March 1997 and 24 June 1997 were assailed before the Court of Appeals. In a resolution dated 1 October 1997, the Court of Appeals referred the matter to the Court of Appeals for proper determination and disposition.

Court of Appeals Ruling

On 20 February 1998, the Court of Appeals rendered its decision setting aside the RTC’s orders dated 6 March 1997 and 24 June 1997. The appellate court held that petitioner’s motion for new trial was filed after the RTC judgment had already become final and executory. It focused on the dates of receipt of the decision: the RTC decision dated 8 April 1996 was received by petitioner’s counsel on 10 April 1996. Petitioner filed the motion for new trial by registered mail on 26 April 1996, which the Court of Appeals regarded as one day late beyond the fifteen-day period. The Court of Appeals accordingly applied the rule that the judgment became final upon expiration of the period to appeal and, being not duly perfected, could not be disturbed through an untimely new trial motion. The Court of Appeals further denied petitioner’s motion for reconsideration by resolution dated 27 July 1998.

The Sole Issue Before the Supreme Court

The Supreme Court treated the case as presenting a sole issue: the timeliness and propriety of petitioner’s motion for new trial. Petitioner asserted that the motion had been timely filed within the fifteen-day period. It argued that while counsel received the decision on 10 April 1996, counsel later disappeared and was never heard of, whereas petitioner received its own copy on 11 April 1996. Petitioner therefore contended that the reckoning point for the reglementary period should be 11 April 1996, not 10 April 1996. It also attributed its procedural predicament to its former counsel’s conduct, including the alleged failure to formally withdraw appearance.

Position of the Parties

Private respondents maintained, as adopted by the Court of Appeals, that service to counsel of record on 10 April 1996 was controlling for purposes of computing the reglementary period. On their view, the motion for new trial filed on 26 April 1996 was one day late, and thus the RTC judgment became final and executory because no proper appeal was perfected.

Petitioner relied on equitable considerations tied to counsel’s alleged failure, urging that it be afforded the chance to present its case. Petitioner invoked the principle from Aguilar v. Court of Appeals, where the Court recognized that losing liberty by default of an insensitive lawyer should be frowned upon despite the fiction that a client is bound by counsel’s mistakes. Petitioner analogized that concern to its situation to seek judicial leniency.

Legal Basis and Reasoning of the Supreme Court

The Supreme Court denied the petition and reaffirmed that the perfection of an appeal in the manner and within the period permitted by law is not only mandatory but jurisdictional. Failure to perfect the appeal within the reglementary period renders the judgment final and executory. The Court emphasized that the procedural requirement rested on public policy and sound judicial practice. The Court observed that the record showed petitioner’s counsel received the decision on 10 April 1996, yet the motion for new trial was filed one day after the expiration of the fifteen-day period. It held that the judgment ipso facto became final when no appeal was perfected after the lapse of the reglementary period, and that the procedural caveat could not be trifled with.

On petitioner’s contention that the period should be counted from 11 April 1996—when petitioner allegedly received its own copy—the Supreme Court ruled that the contention was not correct. It held that service of notice to counsel of record is, for all intents and purposes, notice to the client. It further reasoned that absent a notice of withdrawal or substitution of counsel, the court properly assumes that counsel of record continues to represent the client. Therefore, the date of receipt by the former counsel was the reckoning point.

The Court also noted that even assuming arguendo that the motion for new trial was seasonably filed, the ground invoked by petitioner was not meritorious. It adopted the reasoning of the Court of Appeals, which found that petitioner failed to establish extrinsic fraud to warrant a new trial. Petitioner’s claim of having been fraudulently induced not to file an answer was contradicted by the record: petitioner alleged it could not file an answer because it failed to secure counsel; and the Court of Appeals found that the initiative to settle emanated from private respondents, evidenced by their correspondence offering compromise terms. The appellate court thus rejected the argument that private respondents “enveigled” them into not filing an answer. The Court of Appeals also declined to accept traffic conditions and equipment malfunctions as acts of God, characterizing them as foreseeable events that ordinary prudence could have guarded against. The Supreme Court indicated that these findings undermined the asserted basis for new trial.

Lastly, the Supreme Court addressed

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