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’s lease on his property had expired and she refused to vacate. The MeTC ruled in favor of Santos. Reyes appealed to the Regional Trial Court (RTC), which reversed the MeTC’s 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 on the next working day, Monday. The CA denied the motion, insisting that the reglementary period is absolute and non-extendible. Santos now comes to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals committed a reversible error in dismissing the petition for being filed one day late, considering that the last day for filing fell on a non-working day.

RULING

Yes. The Supreme Court granted the petition and reinstated Santos’s appeal before the Court of Appeals. The Court held that the reglementary period for appealing or filing a petition is subject to the rules on computation of time under the Rules of Court. Applying Section 1, Rule 22, if the last day of the period falls on a Saturday, Sunday, or a legal holiday in the place where the court is located, the time shall not run until the next working day. The CA erred in its rigid application of the reglementary period without considering this rule. The Supreme Court emphasized that while reglementary periods are generally mandatory and jurisdictional, the rules on computation are precisely designed to prevent the loss of a party’s right to appeal due to technicalities when the last day is not a working day. The dismissal was therefore reversed, and the CA was directed to give due course to the petition and resolve it on the merits.