Case Summary (G.R. No. 158941)
Background Facts and SEC Proceedings
Respondents, after failing to receive a response to their demand for rescission, filed a complaint with the SEC against the petitioner and several of its board members for violations of Batas Pambansa Bilang 178. The SEC ruled in favor of the respondents on March 25, 2002, ordering the petitioner to refund the purchase price. Petitioner’s motion for reconsideration was denied, leading to the filing of a Petition for Review with the Court of Appeals (CA), which was late, thus sparking the legal dispute over the timeliness of the appeal.
Court of Appeals and Procedural Issues
The Court of Appeals dismissed the petitioner’s appeal on October 30, 2002, due to its failure to file within the prescribed period as set by the 1997 Revised Rules of Civil Procedure. The CA initially granted a limited (15-day) extension for filing the petition; however, the petitioner filed its petition 25 days late, August 19, 2002. The CA ruled that such delays bar the appeal and render the SEC's decision final and binding.
Issues Raised and Substantive Matters
Petitioner contended that the SEC’s eventual approval of its license had a retroactive effect, thus validating the timeshare agreement and preventing respondents from rescinding the contract. The petitioner argued it had engaged in the sale of the timeshares in compliance with the law before the effective date of its registration.
Legal Principles and Rulings
The Supreme Court observed that a judgment must become final according to the law, and adherence to procedural requirements is essential for an appeal’s validity. It reaffirmed that the petitioner did not meet the stringent requirements of filing an appeal within the periods allowed by law. Furthermore, the Court noted that the SEC’s ruling on the registration’s effectivity clearly stipulated that
...continue readingCase Syllabus (G.R. No. 158941)
Case Background
- The case originates from a Petition for Review on Certiorari filed by Timeshare Realty Corporation (petitioner) against the Court of Appeals (CA) concerning its Resolution dated October 30, 2002.
- The CA denied the appeal of the petitioner from the Securities and Exchange Commission (SEC) Decision dated March 25, 2002, in SEC Case No. 01-99-6199, which favored the respondents, Cesar Lao and Cynthia Cortez.
- The SEC ruled that the petitioner had no authority to sell timeshares, classified as securities, prior to February 11, 1998, which was the effective date of its Registration Statement.
Transactional Facts
- On October 6, 1996, the petitioner sold a timeshare to the respondents for US$7,500, with the payment fully settled within eight months.
- In February 1998, the SEC issued a ruling that the petitioner lacked the requisite authority to sell timeshares prior to February 11, 1998, marking the effective date of its registration.
- The SEC also determined that respondents had the right to unilaterally rescind the purchase agreement and receive a refund, which applied to all agreements made before the effective registration date.
Procedural History
- Following the SEC's ruling, the respondents demanded a refund from the petitioner but received no response.
- They subsequently filed a complaint with the SEC En Banc against the petitio