G.R. No. 100525 May 25, 1993
SOCORRO ABELLA SORIANO, petitioner, vs. COURT OF APPEALS and DEOGRACIAS REYES, respondents.

FACTS

The case originated from an ejectment suit (Civil Case No. 8581) filed by petitioner Socorro Abella Soriano against private respondent Deogracias Reyes in the Municipal Court of Naga City on November 11, 1988, for non-payment of rentals on a month-to-month lease. Private respondent claimed he was a usufructuary, not a tenant. The municipal trial court dismissed the complaint and ordered petitioner to pay attorney’s fees. On appeal, the Regional Trial Court affirmed the dismissal but deleted the attorney’s fees on October 24, 1989. Petitioner then sought to appeal to the Court of Appeals. She filed three successive motions for extension of time to file her petition for review. The Court of Appeals, citing the rule in Lacsamana vs. IAC and its internal rules, denied the third motion and dismissed the proposed petition for review in a resolution dated December 28, 1989, even before the petition was filed. Petitioner filed a motion for reconsideration, explaining that her counsel’s ability to work was adversely affected by exceptional circumstances: the attempted coup d’etat from December 1 to 7, 1989, which created a civil disturbance in Metro Manila; subsequent hostage and labor incidents involving the counsel’s other clients; and a computer breakdown after the Christmas holidays. The Court of Appeals, in a resolution dated June 17, 1991, denied the motion for reconsideration, recognizing that the circumstances from December 1 to 15 could have affected counsel’s work but finding no exceptional circumstances beyond December 15 to justify the further delay. The petition for review was ultimately filed on January 4, 1990. Petitioner then filed a petition for review on certiorari with the Supreme Court.

ISSUE

Whether the Court of Appeals gravely abused its discretion in denying petitioner’s third motion for extension of time to file her petition for review and in dismissing the petition without considering the exceptional circumstances that allegedly prevented timely filing.

RULING

The Supreme Court ruled in favor of the petitioner. The Court annulled and set aside the assailed resolutions of the Court of Appeals dated December 28, 1989 and June 17, 1991. The petition for review in CA-G.R. SP No. 19294 was reinstated, and the Court of Appeals was directed to take appropriate action thereon. The Supreme Court held that while reglementary periods are generally strictly applied, they may be relaxed on equitable considerations to serve the demands of substantial justice. The Court found that the circumstances invoked by petitioner’s counsel—the civil disturbance from the attempted coup, other professional engagements during abnormal situations, and a computer breakdown—constituted a valid justification for the delay. The Court noted that the delay was at most 18 days under abnormal conditions, and that similar delays were incurred by the private respondent and the Court of Appeals itself in the proceedings. Furthermore, the Court found that the case involved substantive issues meriting review, such as the nature of the occupancy (lease vs. usufruct) and the correctness of the lower courts’ factual and legal findings. Therefore, the dismissal of the petition on purely procedural grounds was too harsh a penalty, and a liberal interpretation of the rules was warranted to allow a resolution on the merits.