GR 155086; (March, 2004) (Digest)
G.R. No. 155086 ; March 15, 2004
RUBEN HONGRIA, petitioner, vs. EPITACIA HONGRIA-JUARDE, respondent.
FACTS
Respondent Epitacia Hongria-Juarde filed a forcible entry case against petitioner Ruben Hongria and others, alleging they deprived her of possession of a coconut land. The Municipal Trial Court (MTC) ruled in favor of Ruben Hongria. On appeal, the Regional Trial Court (RTC) reversed the MTC and ordered Epitacia to vacate the land. Epitacia received the RTC decision on September 10, 2001, and filed a motion for reconsideration on September 12, 2001, which the RTC denied in an order dated January 14, 2002. She received notice of this denial on January 22, 2002.
Instead of appealing, Epitacia, through her then-counsel, filed a “Motion for Inhibition & Reconsideration” of the January 14, 2002 denial order on January 24, 2002. This motion was itself denied on April 1, 2002. Epitacia, through a new counsel, subsequently filed a petition for review with the Court of Appeals (CA) via registered mail on April 18, 2002. The CA granted the petition, reversed the RTC, and reinstated the MTC decision. Ruben Hongria appealed to the Supreme Court, contending the CA should not have entertained the petition as it was filed out of time.
ISSUE
Whether the Court of Appeals erred in taking cognizance of the petition for review filed by respondent Epitacia Hongria-Juarde, which was allegedly filed beyond the reglementary period.
RULING
Yes, the Court of Appeals erred. The Supreme Court reversed the CA decision and reinstated the RTC ruling, holding that the petition for review was filed out of time, rendering the RTC decision final and executory. The reglementary period to appeal via a petition for review to the CA is fifteen (15) days from notice of the decision or denial of a timely motion for reconsideration. Epitacia received notice of the denial of her first motion for reconsideration on January 22, 2002. Thus, the fifteen-day period to appeal expired on February 6, 2002.
The subsequent “Motion for Inhibition & Reconsideration” filed on January 24, 2002, was effectively a second motion for reconsideration of the RTC’s main decision, which is a prohibited pleading under the rules. A prohibited motion does not toll the running of the appeal period. Consequently, when Epitacia finally filed her petition for review on April 18, 2002, the RTC decision of September 7, 2001, had long become final and immutable. The CA therefore had no jurisdiction to review the merits of the case. The Supreme Court emphasized the mandatory nature of procedural rules on reglementary periods for appeal, which are designed to ensure the orderly administration of justice.