G.R. No. 139665 ; August 9, 2001
MA. VILMA S. LABAD, petitioner, vs. THE UNIVERSITY OF SOUTHEASTERN PHILIPPINES, THE BOARD OF REGENTS/HON. RICARDO GLORIA (DECS Secretary) Chairman, DR. EDMUNDO B. PRANTILLA, Vice Chairman and USP President, and NEDA DIR. SANTIAGO ENGINCO, JR., Member, and EVA M. ANTEPUESTO, USP PTA-LABORATORY SCHOOL PRESIDENT, ET AL., respondents.

FACTS

Petitioner Ma. Vilma S. Labad was a probationary faculty member at the University of Southeastern Philippines (USP) Laboratory School. She was designated as an adviser for the school’s yearbook, regular school organ, and student government. On February 1, 1996, the USP Parents Teachers Association filed a letter-complaint charging her with Dishonesty, Grave Misconduct, and Unfitness as a Teacher, citing specific allegations including misrepresentation of printing costs, violations of the Campus Journalism Act, physical and emotional mistreatment of students, illegal collections, and failure rates. An Investigating Committee was created, which recommended her dismissal through non-renewal of her probationary status. The USP Board of Regents approved this decision. Petitioner appealed to the Civil Service Commission (CSC), which affirmed the decision on April 14, 1998, and denied her motion for reconsideration in a Resolution dated November 13, 1998, which she received on December 11, 1998. On December 28, 1998, petitioner filed a Motion for Extension of Period to File Petition for Review with the Court of Appeals, asking for 15 days from December 28, 1998, or until January 12, 1999. The Court of Appeals, in a Resolution dated January 28, 1999, granted an extension of 15 days from December 26, 1998, or until January 10, 1999. Petitioner filed her Petition for Review on January 12, 1999. The Court of Appeals dismissed the petition for being filed late (beyond the extended period of January 10, 1999) in a Resolution dated February 24, 1999, and denied her motion for reconsideration in a Resolution dated July 22, 1999. Hence, this petition for review on certiorari.

ISSUE

The primary issue, as resolved by the Supreme Court, is whether the Court of Appeals correctly dismissed petitioner’s appeal for being filed out of time, specifically concerning the computation of the extended period granted for filing the petition for review.

RULING

The Supreme Court GRANTED the petition and REMANDED the case to the Court of Appeals for further proceedings. The Court ruled that the Court of Appeals erred in dismissing the petition for review. The Court held that when a motion for extension of time to file a petition is filed within the reglementary period, it is the period requested in the motion, and not the period granted by the court, that should be considered in determining the timeliness of the filing if the petition is filed within the requested extension period. Petitioner filed her motion for extension on December 28, 1998, within the 15-day reglementary period from her receipt of the CSC Resolution on December 11, 1998. She requested an extension of 15 days from December 28, 1998, or until January 12, 1999. She filed her petition on January 12, 1999, which was within her requested period. Therefore, her petition was timely filed. The Court found that the appellate court’s grant of an extension from a different starting date (December 26, 1998) was a unilateral alteration that could not prejudice the petitioner who had relied on her motion and filed within the period she sought. The Court emphasized that rules of procedure should be liberally construed to promote their objective of securing a just, speedy, and inexpensive disposition of every action.