GR No. 123456, *Santos v. Reyes* (2020)

FACTS: Juan Santos filed a complaint for ejectment against Maria Reyes before the Metropolitan Trial Court (MeTC), alleging that Reyes was unlawfully withholding possession of a residential property. The MeTC ruled in favor of Santos. Reyes appealed to the Regional Trial Court (RTC), which reversed the MeTC decision. Santos then filed a Petition for Review with the Court of Appeals (CA). The CA dismissed the petition for being filed one day late. Santos filed a Motion for Reconsideration, arguing that the last day for filing fell on a Saturday and that he filed the petition on the next working day, Monday. The CA denied the motion, insisting that the reglementary period is absolute and non-extendible. Santos now elevates the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether or not the Court of Appeals erred in dismissing the petition for being filed one day late, considering that the last day for filing fell on a Saturday.

RULING

Yes, the Court of Appeals erred. The Supreme Court granted the petition and reinstated Santos’s appeal before the CA. Under Section 1, Rule 22 of the Rules of Court, if the last day of the period to do an act is a Saturday, a Sunday, or a legal holiday, the time shall not run until the next working day. This is a well-established rule intended to prevent a party from losing his right to appeal due to the inaccessibility of courts on non-working days. The CA’s strict application of the reglementary period, without considering this exception, constituted a grave abuse of discretion. The period to file the Petition for Review with the CA was therefore extended to the next working day following the Saturday deadline, making Santos’s filing timely.