GR 185220; (July, 2009) (Digest)
G.R. No. 185220 ; July 27, 2009
LAGUNA METTS CORPORATION, Petitioner, vs. COURT OF APPEALS, ARIES C. CAALAM and GERALDINE ESGUERRA, Respondents.
FACTS
Private respondents Aries C. Caalam and Geraldine Esguerra filed a labor case against petitioner Laguna Metts Corporation (LMC) for illegal dismissal. The Labor Arbiter ruled in their favor, but the National Labor Relations Commission (NLRC) reversed this decision on appeal. The NLRC resolution denying their motion for reconsideration was received by their counsel on May 26, 2008. On the last day of the 60-day reglementary period, July 25, 2008, they filed a motion for a 15-day extension to file a petition for certiorari under Rule 65 with the Court of Appeals. The appellate court granted the motion.
LMC moved for reconsideration, arguing that extensions of time to file a petition for certiorari were no longer permitted under the amended Section 4, Rule 65 of the Rules of Court. The Court of Appeals denied LMC’s motion, holding that while the amendment called for stricter application, it did not divest the court of its discretionary power to grant extensions in exceptional cases to serve the ends of justice. LMC elevated the matter to the Supreme Court via a petition for certiorari.
ISSUE
Whether the Court of Appeals committed grave abuse of discretion in granting a motion for extension of time to file a petition for certiorari under Rule 65.
RULING
Yes. The Supreme Court granted LMC’s petition, reversing the Court of Appeals’ resolutions. The legal logic is anchored on the mandatory nature of procedural rules, particularly those prescribing time periods for specific acts. The Court emphasized that the 60-day period for filing a petition for certiorari is reasonable and designed to prevent unreasonable delays, ensuring the constitutional right to a speedy case disposition. The critical analysis focused on the amendment to Section 4, Rule 65 by A.M. No. 07-7-12-SC, which took effect on December 27, 2007. The old rule explicitly allowed for an extension “except for compelling reason and in no case exceeding 15 days.” This entire provision was deleted in the amended rule. The deletion is presumed intentional, indicating a deliberate change in meaning. The amended rule, by omitting the clause permitting extensions, now absolutely disallows any extension of the 60-day period. The Court of Appeals, therefore, had no discretion to grant the motion. Rules of procedure are indispensable for orderly judicial business and must be faithfully observed by all parties, regardless of their circumstances. The petition filed by the private respondents was consequently filed out of time.