GR 203918; (December, 2015) (Digest)
G.R. No. 203918, December 02, 2015
SPOUSES AMADOR C. CAYAGO, JR. AND ERMALINDA B. CAYAGO, PETITIONERS, VS. SPOUSES EVELITO CANTARA AND SOLEDAD CANTARA, RESPONDENTS.
FACTS
Respondents Spouses Cantara filed a complaint for forcible entry against petitioners Spouses Cayago before the Municipal Trial Court (MTC). The Cantaras claimed prior physical possession of a riceland since 1993, purchased from a predecessor, and alleged that the Cayagos forcibly entered and cultivated the land in December 2007. The Cayagos defended their claim by presenting an Original Certificate of Title (OCT) and tax declarations, asserting ownership and possession since 1948. The MTC dismissed the complaint, favoring the Cayagos. On appeal, the Regional Trial Court (RTC) reversed the MTC, awarding possession to the Cantaras and ordering the Cayagos to vacate and pay rent. The Cayagos’ motion for reconsideration was denied by the RTC in an Order received on July 15, 2010.
The Cayagos had until July 30, 2010, to file a petition for review with the Court of Appeals (CA). On July 29, 2010, they filed a motion for a 15-day extension. The CA granted the motion. The Cayagos filed their petition on August 14, 2010. The CA later dismissed the petition as belatedly filed, ruling that the extension motion was filed only one day before the reglementary period expired, which was insufficient under the rules.
ISSUE
Whether the Court of Appeals correctly dismissed the petition for review for having been filed out of time.
RULING
No. The Supreme Court reversed the CA and reinstated the petition. The Court clarified the procedural rule under Section 1, Rule 42 of the Rules of Court. A party may file a motion for a 15-day extension to file a petition for review, provided it is filed before the expiration of the original 15-day reglementary period and accompanied by payment of fees. The rule does not require the motion to be filed a specific number of days in advance of the deadline. Filing it even one day before expiration is timely, as the provision only prescribes the outer limit—that it must be filed before the period lapses.
The Cayagos complied with this requirement by filing their motion and paying fees on July 29, 2010, which was within the reglementary period ending July 30. The CA’s imposition of an additional requirement—that the motion be filed several days before the deadline—was a misapplication of the rule that unduly restricted the right to appeal. Since the motion was proper, the extension granted was valid, making the petition filed on August 14 timely. The Court emphasized that rules of procedure should be liberally construed to secure just, speedy, and inexpensive disposition of cases, especially where a strict interpretation would deny a party their day in court on a mere technicality. The case was remanded to the CA for resolution on the merits.