Case Summary (G.R. No. 237591)

Court's Duty to Render Justice

• The Court emphasizes its primary responsibility to deliver justice without being hindered by technicalities.
• It acknowledges that a belated appeal may be considered if substantial justice and public interest are at stake.

Background of the Case

• The Subic Bay Metropolitan Authority (SBMA) was established under Republic Act No. 7227 to manage the Subic Special Economic Zone (SBFZ).
• SBMA is tasked with developing the SBFZ into a self-sustaining economic center, providing municipal services funded by its own revenues.
• To recover costs for municipal services, SBMA imposed a Common User Service Area (CUSA) Fee on its direct tenants.

Implementation of the CUSA Fee

• SBMA's Board approved the CUSA Fee policy on April 13, 2012, and informed lessees through public hearings and written communications.
• The Office of the President issued Administrative Order No. 31, authorizing SBMA to rationalize and impose new fees, reinforcing its authority to collect the CUSA Fee.

Legal Challenge by SBMEI

• Subic Bay Marine Exploratorium, Inc. (SBMEI), a lessee in the SBFZ, filed a complaint against SBMA, seeking to nullify the CUSA Fee as unconstitutional.
• SBMA responded by asserting that SBMEI failed to exhaust administrative remedies and that the CUSA Fee was lawful under existing laws.

Ruling of the Regional Trial Court (RTC)

• The RTC ruled in favor of SBMEI, annulling the CUSA Fee and permanently enjoining SBMA from its collection.
• SBMA's subsequent motions for reconsideration were denied, leading to a late notice of appeal being filed.

Denial of SBMA's Notice of Appeal

• The RTC denied SBMA's notice of appeal as it was filed one day late, emphasizing strict adherence to the reglementary period.
• SBMA's explanations for the delay were dismissed, leading to further motions for reconsideration being denied.

Appeal to the Court of Appeals (CA)

• SBMA filed a petition for certiorari with the CA, which upheld the RTC's decision, stating that the delay in filing the notice of appeal was unjustified.
• The CA affirmed the RTC's orders, leading SBMA to seek further review from the Supreme Court.

Issue of the Appeal's Due Course

• The central issue was whether SBMA's appeal could be given due course despite the one-day delay.
• SBMA argued that the delay was due to a clerical error and that its right to appeal should not be forfeited due to this mistake.

Ruling of the Supreme Court

• The Supreme Court found merit in SBMA's petition, emphasizing that procedural rules should yield to substantial justice.
• The Court highlighted that the right to appeal is a statutory privilege and that strict adherence to procedural rules should not hinder justice.

Justification for Relaxing Procedural Rules

• The Court noted that the negligence of SBMA's clerk and handling lawyer should not prejudice SBMA's rights, especially given the substantial governmental interest involved.
• The Court referenced previous cases where delays were excused due to compelling reasons and the need for justice.

Implications of the CUSA Fee

• The Court recognized the significant financial implications for SBMA and the national government if the CUSA Fee was invalidated.
• SBMA's annual expenses for municipal services were substantial, and the collection of the CUSA Fee was crit...continue reading