DISPOSITIVE:

“WHEREFORE, the petition is GRANTED. The Decision dated

September 24, 2020, and the Resolution dated February 16, 2022, of the

Court of Appeals in CA-G.R. SP No. 153869, and the Order dated

September 18, 201 7, and the Decision dated September 18, 2017, of

Branch 62, Regional Trial Court, Makati City, in Civil Case No. 02-683

are SET ASIDE.

Accordingly, the Complaint for deficiency claim in Civil Case No.

02-683 is DISMISSED.

SO ORDERED.”

SUBJECTS/DOCTRINES/DIGEST:

Indeed, the RTC is given considerable discretion in deciding

whether a case before it should be dismissed with or without prejudice. It

must be stressed, however, that the exercise of judicial discretion must not

violate Section 16, Article III of the Constitution which provides that “[a]ll

persons shall have the right to a speedy disposition of their cases before

all judicial, quasi-judicial, or administrative bodies.” Courts should decide

cases judiciously and expeditiously as a matter of course keeping in mind

the adage, “justice delayed is justice denied.”

Here, SPV-AMC, Inc. ‘s delay in prosecuting its action is

inexcusable. It is incredulous that the archival period of the case was

longer than the 10-year-prescriptive period on the enforcement of the

promissory notes. 86 Evidently, SPV-AMC and SPV-AMC, Inc. had all the

opportunity in the world to prove their deficiency claim by preponderant

evidence and still failed to do so. Having ruled on the merits of the case

and finding SPV-AMC, Inc.’s evidence insufficient to justify its deficiency

claim, the RTC should have dismissed the Complaint with prejudice.

Considering that the case had already been archived for more than

10 years, the Court rules that the RTC’s order of dismissal without

prejudice after trial on the merits is a violation of petitioners’ right to

speedy disposition of their case, and thus, cannot be sanctioned by the

Court. More, there will be no end to litigation and the courts’ dockets

would be clogged if plaintiffs who, by their own fault, failed to

substantiate their claims after trial on the merits would be allowed to

re-file their case to the prejudice of the defendant.

On a final note, “[t]he expeditious disposition of cases is as much

the duty of the plaintiff as the court’s.” 87 SPV-AMC Inc. ‘s delay in

prosecuting its action for an unreasonable length of time is highly

prejudicial to petitioners whose loan obligation continued ballooning

while the case is pending. The Court cannot, in good conscience, make

petitioners suffer for the negligence of SPV-AMC and SPV-AMC, Inc.

TO READ THE DECISION, JUST CLICK/DOWNLOAD THE FILE BELOW. IF FILE DOES NOT APPEAR ON SCREEN GO TO DOWNLOAD. IT IS THE FIRST ITEM. OPEN IT.

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