G.R. No. 157020 ; June 19, 2013
REINIER PACIFIC INTERNATIONAL SHIPPING, INC. and NEPTUNE SHIP MANAGEMENT SVCS., PTE., LTD., Petitioners, vs. CAPTAIN FRANCISCO B. GUEVARRA, Respondents.

FACTS

Petitioner Reinier Pacific International Shipping, Inc., as agent for its principal, hired respondent Captain Francisco B. Guevarra as a ship master. Guevarra was later relieved of command following alleged negligence causing damage to the vessel, leading him to file an illegal dismissal case. The Labor Arbiter ruled in Guevarra’s favor, a decision affirmed by the National Labor Relations Commission (NLRC) on February 22, 2002. The last day to file a petition for certiorari with the Court of Appeals (CA) was July 26, 2002 (a Friday). Petitioners secured a 15-day extension, which, counted from July 26, fell due on August 10, 2002 (a Saturday). They filed their petition on the next working day, Monday, August 12, 2002.
The CA dismissed the petition as filed out of time. It applied A.M. No. 00-2-14-SC, which clarifies that when an extension of time is granted, the new due date is calculated from the original expiration of the period, and the rule extending the deadline to the next working day if the last day falls on a Saturday no longer applies. The CA concluded that since the extended due date (August 10) was a Saturday, petitioners should have filed by the previous Friday, August 9.

ISSUE

Whether the Court of Appeals erred in dismissing the petition for certiorari for having been filed out of time.

RULING

Yes, the Court of Appeals erred. The Supreme Court reversed the CA’s dismissal, holding that the petition was timely filed on Monday, August 12, 2002. The Court explained that A.M. No. 00-2-14-SC was intended to correct the erroneous practice of reckoning the start of an extended period from the next working day after a Saturday, Sunday, or holiday. The correct rule is that an extension is counted from the original expiration date of the period, regardless of whether that date is a non-working day.
However, this clarification does not mean a party is deprived of the full benefit of the granted extension or is compelled to file on a day when courts are closed. In this case, the 15-day extension, counted from the original last day (July 26), ended on August 10, a Saturday. Since courts are closed on Saturdays, Section 1, Rule 22 of the Rules of Court applies: if the last day of the period falls on a Saturday, the time shall not run until the next working day. Therefore, the filing on the next working day, Monday, August 12, was timely. The CA’s interpretation would have unjustly shortened the granted extension by one day, contravening procedural due process. The petition was thus filed within the properly computed period.