G.R. No. L-16355-56; April 28, 1961
IGNACIO GONZALES, petitioner, vs. HON. JOSE M. SANTOS, ET AL., respondents.

FACTS

On March 24, 1958, petitioner Ignacio Gonzales filed six petitions with the Court of Agrarian Relations (CAR) in Cabanatuan City to eject his tenants. The tenants denied the allegations and filed a counterclaim for recovery of excess rentals paid under a prior leasehold agreement. Separately, the tenants also filed a petition for liquidation of harvests for two agricultural years, alleging they had given Gonzales more than his due share. Gonzales denied these claims. The CAR heard these interrelated cases jointly and rendered a consolidated decision dismissing both the ejectment petitions and the tenants’ counterclaim, except for one tenant, Jose Esguerra, whose tenancy was declared extinguished but with a provision allowing his son to succeed him.
On November 20, 1959, Gonzales moved for a 15-day extension to file a motion for reconsideration, citing pressure of work and the voluminous case records. The CAR denied this motion, ruling it had no power to extend the period for filing such a motion. Gonzales’s motion for reconsideration of this denial was also rejected. He then filed this certiorari petition, contending the respondent judge acted with grave abuse of discretion or in excess of jurisdiction.

ISSUE

Whether the Court of Agrarian Relations has the power to grant an extension of time to file a motion for reconsideration of its decision.

RULING

Yes. The Supreme Court granted the petition, holding that the agrarian court committed grave abuse of discretion in denying the motion for extension. The legal logic is anchored on the statutory right to appeal and the inherent powers of the court. Under Section 13 of Act No. 1267, as amended, a party may appeal from a CAR decision to the Supreme Court within 15 days from notice. Section 12 further provides that the decision becomes final after 15 days unless a motion for reconsideration is filed within that period. This right to move for reconsideration inherently includes the right to seek an extension of the period for filing it when necessary, such as due to the complexity of the case or voluminous records. Denying this right would nullify the statutory remedy.
Moreover, Section 8 of Republic Act No. 1267 grants the CAR all the inherent powers of a regular court under the Rules of Court, including the power “to amend and control its processes and orders so as to make them conformable to law and justice.” This broad grant encompasses the authority to extend time for filing pleadings, such as a motion for reconsideration, as recognized in jurisprudence for regular courts. The Supreme Court found no cogent reason to withhold such a procedural power from the agrarian court, especially when exercised to serve justice and allow the lower court an opportunity to correct potential errors. Since Gonzales’s motion for extension was filed within the original 15-day period and for valid cause, the CAR’s denial based on a perceived lack of power constituted an error tantamount to abuse of discretion. The Court set aside the CAR’s order and remanded the case for proper action on the motion for extension.