G.R. No. L-16757; November 29, 1963
J. M. TUASON & CO., INC., plaintiff-appellee, vs. CORNELIO M. AGUILA, defendant-appellant.

FACTS

J.M. Tuason & Co., Inc. filed an action for recovery of possession of a parcel of land in Quezon City against Cornelio M. Aguila. The defendant moved to dismiss, arguing that a prior compromise agreement in another case acknowledged his right to possess the property. The trial court denied the motion, proceeded to trial, and rendered a decision on September 8, 1959, ordering Aguila to vacate the land. Aguila received a copy of this decision on September 14, 1959.
Aguila filed a motion for new trial on September 30, 1959, which was denied on December 28, 1959. He then attempted to appeal the main decision, but this appeal was disapproved for being perfected beyond the reglementary period, causing the judgment to become final and executory. Subsequently, on January 5, 1960, Aguila filed an “urgent motion for relief” from the September 8, 1959 decision.

ISSUE

Whether the trial court correctly denied the defendant’s motion for relief from judgment.

RULING

Yes, the trial court correctly denied the motion. The Supreme Court affirmed the denial, holding that the motion for relief was filed out of time. Under Rule 38, Section 3 of the Rules of Court, a petition for relief from judgment must be filed within sixty (60) days from the date the petitioner learns of the judgment, order, or other proceeding to be set aside, and not more than six (6) months from entry of said judgment or order. The record shows counsel for Aguila received the copy of the adverse decision on September 14, 1959. The motion for relief was filed only on January 5, 1960, which was clearly beyond the 60-day period prescribed by the rules. The trial court’s order of denial was therefore in strict accordance with procedural law.
The appellant argued that his former counsel committed a mistake by filing a motion for relief instead of a second motion for new trial, and requested the Court to treat it as such in the interest of substantial justice, disregarding procedural technicalities. The Supreme Court rejected this plea. It found no justifiable reason to re-characterize the motion, as the grounds alleged in the motion for relief were not those exclusively allowable for a new trial under the rules. The Court emphasized that while technicalities may at times be relaxed, the reglementary periods for appeals and related remedies are indispensable to the orderly administration of justice and the stability of final judgments. Since the motion was procedurally infirm, the appeal was dismissed for lack of merit.