G.R. No. 135959 May 11, 2000
HEIRS OF ANDREA CRISTOBAL, represented by AMADO DE LEON, petitioners, vs. COURT OF APPEALS, ROSARIO LOPEZ and ALICIA SANTOS, respondents.

FACTS

Petitioners, the Heirs of Andrea Cristobal, filed an application for land registration in 1975. Respondents Rosario Lopez and Alicia Santos filed oppositions, with Santos later filing her own separate application for registration over a portion of the same land. The cases were consolidated. The Regional Trial Court ruled in favor of the petitioners. On appeal, the Court of Appeals reversed the trial court’s decision in a ruling promulgated on August 31, 1998.
A copy of the appellate court’s decision was received at the law office of petitioners’ counsel, Atty. Lumen Policarpio, on September 9, 1998. However, her office was closed due to her confinement for a serious medical condition. The decision was forwarded to her residence and received by her nurse on September 13, 1998. Instead of filing a motion for reconsideration within the 15-day reglementary period, petitioners filed a motion for a 30-day extension to file such motion, citing their counsel’s illness. The Court of Appeals denied the motion for extension.

ISSUE

Whether the Court of Appeals committed reversible error in denying petitioners’ motion for extension of time to file a motion for reconsideration.

RULING

The Court of Appeals did not err. The denial was proper and in strict adherence to procedural rules. Under Section 2, Rule 9 of the Revised Internal Rules of the Court of Appeals (RIRCA), a motion for reconsideration must be filed within fifteen (15) days from notice, and this period is expressly “non-extendible.” This rule implements the doctrine established in Habaluyas Enterprises, Inc. v. Japson, which categorically prohibits the filing of motions for extension of time to file a motion for new trial or reconsideration in any court except the Supreme Court.
The legal logic is clear: procedural rules on reglementary periods are mandatory and jurisdictional to ensure the orderly administration of justice. The Court rejected the plea for an exception based on counsel’s illness. The records indicated the law office had been closed for months prior to the decision’s promulgation. This interval provided ample opportunity for the law firm to manage its caseload, delegate responsibilities among associates, or for the clients to seek alternative representation to protect their interests. A client is bound by the negligence of counsel, and the failure to adopt such contingency measures does not constitute a compelling reason to relax a mandatory rule. The Court emphasized that while it advocates a liberal application of procedural rules to achieve substantial justice, this cannot be invoked when it would override a clear and mandatory prohibition designed to prevent indefinite delays. Consequently, the appellate court’s decision had become final and executory.