GR 159708; (September, 2004) (Digest)
G.R. No. 159708 ; September 24, 2004
Jaime Beltran Luz, petitioner, vs. National Amnesty Commission, respondent.
FACTS
Petitioner Jaime Beltran Luz was charged with illegal possession of firearms. His application for amnesty was denied by the Local Amnesty Board, a decision affirmed by the National Amnesty Commission (NAC) in a resolution received by Luz on November 22, 2002. Under NAC rules, he had until December 7, 2002, a Saturday, to file a petition for review with the Court of Appeals (CA). On December 9, 2002, Luz filed a motion for a 15-day extension, which the CA later granted but counted from the original deadline of December 7, making the new deadline December 22, 2002.
Luz failed to meet this extended deadline. He filed a second motion for extension on December 26, 2002, and subsequently filed his petition on January 10, 2003. The CA denied the second motion, ruling it was filed out of time. Luz moved for reconsideration, arguing that under Rule 22, Section 1 of the Rules of Court, the original deadline should have moved to the next working day (December 9), making his first motion timely and his subsequent filings valid.
ISSUE
Whether the Court of Appeals erred in denying the petitioner’s second motion for extension of time to file his petition for review.
RULING
The Supreme Court granted the petition, reversing the CA. The Court acknowledged that under A.M. No. 00-2-14-SC, when an extension is granted, it is generally counted from the original expiration date, even if that date is a non-working day. This rule was correctly applied by the CA in reckoning the first extension from December 7, 2002.
However, the Court exercised its equity jurisdiction and applied a liberal interpretation of the procedural rules to achieve substantial justice. The Court considered that Luz’s counsel relied in good faith on a prior ruling (Moskowsky v. Court of Appeals) which supported a different computation. Furthermore, Luz had already filed his petition for review on January 10, 2003, before the CA even resolved his first motion for extension, demonstrating a desire to comply with the appellate process. The right to appeal, while statutory, should not be denied on overly technical grounds where no intent to delay is apparent and liberality would serve the ends of justice. Thus, the petition was admitted.