G.R. No. 172418 ; July 9, 2012
NEMESIO V. SAYCON (deceased), substituted by his heirs, et al., Petitioners, vs. ANACLETA BAROT VDA. DE TULABING, et al., Respondents.

FACTS

Respondents, heirs of Alejandro Tulabing, filed an ejectment and recovery of possession case against petitioners. They alleged that since 1950, Alejandro had been in possession of a 12-hectare fishpond. In 1970, Alejandro leased a 4-hectare portion to petitioner Nemesio Saycon under a contract renewed in 1977. Upon the lease’s expiration and Alejandro’s death, respondents demanded possession and unpaid rentals, but petitioners refused to vacate. Petitioners countered that the fishpond they occupied was distinct, claimed possession since 1969, and argued the leased portion was part of a 7-hectare property Alejandro sold to a third party in 1980.
The Regional Trial Court (RTC) ruled for respondents, ordering petitioners to vacate and pay rentals. The Court of Appeals (CA) initially remanded the case to the RTC, finding respondents’ evidence insufficient to definitively identify the property sought to be recovered. On remand, the RTC issued a Supplemental Decision positively identifying the land using tax declarations and survey plans. The CA subsequently affirmed the RTC’s decisions. Petitioners then filed a Motion for Reconsideration, which the CA denied in a Resolution dated March 23, 2006. This petition for review assails that CA denial.

ISSUE

Whether the Supreme Court should give due course to the petition for review filed by the petitioners.

RULING

No. The Supreme Court denied the petition for being filed out of time, rendering a review of the substantive merits unnecessary. Procedural rules on reglementary periods are mandatory and jurisdictional. The Court meticulously computed the filing period: the 15-day period to appeal from the CA’s March 23, 2006 Resolution expired on April 7, 2006. The Court granted petitioners two motions for extension totaling 45 days, with the final deadline set on May 29, 2006, counting from April 14, 2006. The Court explicitly warned that no further extension would be granted. Petitioners filed their petition only on May 30, 2006, one day beyond the absolute deadline. The Court emphasized that the reglementary period, once lapsed, deprives it of jurisdiction to entertain the appeal. The liberal application of procedural rules cannot be invoked to rescue a party from negligence or to validate a belated filing that disregards a final warning from the Court. Consequently, the CA Resolutions dated August 11, 2005 and March 23, 2006 were affirmed.