MANUEL R. MACARANAS, JR., DOING BUSINESS UNDER THE NAME ESTILO DECADA VS. CONRADO L. TIU AND DOLORES L. TIU RESPONDENTS.

Macaranas versus Tiu

The Case

This is the case of Macaranas versus Tiu, a civil action for damages and other reliefs brought by Manuel R. Macaranas, Jr., doing business under the name Estilo Decada, against Conrado L. Tiu and Dolores L. Tiu. The decision before us, however, is not a ruling on the merits of that complaint. It is a resolution of a much narrower and highly examinable question of procedure: whether a motion for reconsideration filed four days beyond the reglementary period may be excused on a claim of inadvertence, excusable neglect, and oversight by counsel's secretary, who supposedly sent the motion through a private courier. The case matters because it restates, in the Court's own words, the strict standard for relaxing procedural rules, and because it shows how the Court measures a plea for liberal construction against the factual circumstances of the case invoked as precedent.

Procedural History

The case began in the trial court as a complaint for damages and other reliefs filed by Macaranas against the spouses Tiu. The case reached the Supreme Court, which rendered a Decision dated 08 October 2014. The respondents, the spouses Tiu, then filed a motion for reconsideration of that Decision, but the motion was filed four days late. The Supreme Court denied the motion for reconsideration for being filed out of time. From that denial, the respondents moved for reconsideration of the denial itself, explaining that the delay in filing their earlier motion was due to inadvertence, excusable neglect, and oversight by counsel's secretary when she sent the copy of the motion through a private courier. Citing the case of Sy versus the Local Government of Quezon City, the respondents prayed that the rules be relaxed. Macaranas opposed the motion. The Court then resolved the second motion for reconsideration in the decision now before us.

Facts

Macaranas sued the spouses Tiu for damages and other reliefs. The Supreme Court decided the case against the respondents through a Decision dated 08 October 2014. The respondents sought reconsideration of that Decision, but their motion was filed four days after the period allowed by the rules had expired.

The Court denied the motion for being filed out of time. The respondents then asked the Court to reconsider that denial. They blamed the delay on the secretary of their counsel, who, they said, sent the copy of the motion through a private courier. They characterized the lapse as inadvertence, excusable neglect, and oversight, and they invoked the Sy case to ask for a relaxation of the rules.

Macaranas opposed the motion. The Court examined the explanation against the standard of care required of litigants and their counsel, and against the factual setting of the Sy case, which the respondents had placed at the center of their plea.

Issues

• Whether or not the late filing of the motion for reconsideration may be excused on the ground of inadvertence, excusable neglect, and oversight by counsel's secretary in sending the motion through a private courier.
• Whether or not the relaxation of the rules allowed in the Sy case may be applied to the respondents' situation.

Applicable Provisions

The decision does not quote a specific statutory provision. It applies the settled rule on excusable negligence as a ground for relaxing procedural rules, which the Court states in its own words:

A claim of excusable negligence does not loosely warrant a relaxation of the rules.

This rule bears on the case because the respondents anchored their plea for relief precisely on a claim of excusable neglect, and the Court measured their explanation against this standard.

The Court also states the measure of care required of a party invoking excusable negligence:

The standard of care required is that which an ordinarily prudent man bestows upon his important business.

This standard governs whether the courier mistake may be treated as unforeseen and therefore excusable.

Finally, the Court states the duty of counsel in relation to filing and service:

It is the duty of counsel to adopt and strictly maintain a system that insures that all pleadings should be filed and duly served within the period therefor.

This duty is the reason the secretary's oversight is charged to the respondents and cannot excuse their late filing.

Ruling

On the first issue, the Court held that the late filing of the motion for reconsideration cannot be excused. A claim of excusable negligence, the Court stressed, does not loosely warrant a relaxation of the rules. The party invoking it must show that the procedural oversight or lapse was attended by a genuine miscalculation or unforeseen fortuitousness which ordinary prudence could not have guarded against. The standard of care is that which an ordinarily prudent man bestows upon his important business. Measured against that standard, the mistake of sending the motion through a private courier was not unforeseen and could have been prevented by ordinary prudence. Counsel has the duty to adopt and strictly maintain a system that insures that all pleadings are filed and duly served within the period.

On the second issue, the Court held that the relaxation of the rules in the Sy case may not be applied, because the circumstances there are not similar to those of the respondents. In Sy, the motion for reconsideration was filed only one day late, while in this case it was filed four days late. Moreover, the Supreme Court in Sy found persuasive reasons to relax the rules, and the Court found no such justifications in the respondents' case.

Doctrine

A claim of excusable negligence does not, by itself, justify a relaxation of procedural rules. The party invoking it must show that the procedural lapse was attended by a genuine miscalculation or unforeseen fortuitousness which ordinary prudence could not have guarded against. The required standard of care is that which an ordinarily prudent man bestows upon his important business.

It is the duty of counsel to adopt and strictly maintain a system that insures that all pleadings are filed and duly served within the period. The negligence of counsel's staff in transmitting a pleading is charged to the client and does not excuse a late filing.

Relaxation of the rules is not a matter of course. A precedent allowing relaxation applies only when the circumstances are comparable, and the length of the delay and the presence of persuasive reasons are material points of comparison.

Disposition

The Court denied the respondents' motion for reconsideration for lack of merit, so Macaranas prevailed and the denial of the respondents' earlier motion for being filed out of time stood.

Remember This

Memorize the line that a claim of excusable negligence does not loosely warrant a relaxation of the rules, and that counsel must strictly maintain a system ensuring timely filing and service. Examiners use this case to test the strict standard for excusable neglect and the limits of relaxing procedural rules based on a precedent with different circumstances.