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GUASCH vs. DELA CRUZ 589 SCRA 297
GUASCH vs. DELA CRUZ 589 SCRA 297
In November 2000, respondent Arnaldo dela Cruz filed a Complaint-Affidavit against petitioner Mercedita T. Guasch with the City Prosecutor of Manila. Respondent alleged that petitioner was his neighbor and kumadre. On several occasions, petitioner transacted business with him by exchanging cash for checks of small amount without interest. In July 1999, petitioner went to his residence requesting him to exchange her check with cash of P3,300,000.00. On the date of maturity and upon presentment, however, the check was dishonored for the reason that the account against which it was drawn was already closed. In 2002, the City Prosecutor filed an Information for estafa against petitioner. The trial court issued an Order granting the demurrer to evidence and dismissing the case. The trial court found that respondent's assertion of misrepresentation by petitioner that her check will be fully funded on the maturity date was not supported by the evidence on record. Accordingly, her guilt not having been proven beyond reasonable doubt, petitioner was acquitted. In the Manifestation, respondent's counsel justified his failure to file the motion within the reglementary period of 15 days because all postal offices in Metro Manila were allegedly ordered closed in the afternoon due to the rally staged on Ayala Avenue. Respondent filed a Petition for Certiorari with the Court of Appeals and ruled that the trial court did not anchor the acquittal of petitioner on evidence other than that presented by the prosecution as contended by petitioner and was tainted with grave abuse of discretion on denial of respondent's Motion. Hence, this petition.
Whether or not, the Court of Appeals erred in holding that the trial court committed grave abuse of discretion when it denied respondent's Motion to Amend.
As a general rule, the statutory requirement that when no motion for reconsideration is filed within the reglementary period, the decision attains finality and becomes executory in due course must be strictly enforced as they are considered indispensable interdictions against needless delays and for orderly discharge of judicial business. The purposes for such statutory requirement are twofold: first, to avoid delay in the administration of justice and thus, procedurally, to make orderly the discharge of judicial business, and, second, to put an end to judicial controversies, at the risk of occasional errors, which are precisely why courts exist. Controversies cannot drag on indefinitely. The rights and obligations of every litigant must not hang in suspense for an indefinite period of time. However, in exceptional cases, substantial justice and equity considerations warrant the giving of due course to an appeal by suspending the enforcement of statutory and mandatory rules of procedure. Certain elements are considered for the appeal to be given due course, such as: (1) the existence of special or compelling circumstances, (2) the merits of the case, (3) a cause not entirely attributable to the fault or negligence of the party favored by the suspension of the rules, (4) lack of any showing that the review sought is merely frivolous and dilatory, and (5) the other party will not be unduly prejudiced thereby. As we ruled in Gayos v. Gayos, "it is a cherished rule of procedure that a court should always strive to settle the entire controversy in a single proceeding leaving no root or branch to bear the seeds of future litigation." Given the circumstances in this case, we find that the trial court committed grave abuse of discretion when it denied respondent's Motion to Amend
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