G.R. No. L-70895 May 30, 1986
HABALUYAS ENTERPRISES, INC. and PEDRO HABALUYAS, petitioners, vs. JUDGE MAXIMO M. JAPSON, Manila Regional Trial Court, Branch 36; SHUGO NODA & CO., LTD., and SHUYA NODA, respondents.

FACTS

This case originated from a petition for certiorari and prohibition filed by Habaluyas Enterprises, Inc. and Pedro Habaluyas. The petition challenged the order of respondent Judge Maximo M. Japson of the Manila Regional Trial Court, which had granted the private respondents’ (Shugo Noda & Co., Ltd. and Shuya Noda) motion for a new trial. The Second Division of the Supreme Court initially granted the petition on August 5, 1985, setting aside the trial court’s order. The core issue prompting the reconsideration was whether the fifteen-day period for filing a motion for reconsideration of a final Regional Trial Court order, as established by Batas Pambansa Blg. 129, could be extended. The private respondents had filed a motion for extension of time to file their motion for reconsideration, which the trial court granted.
The procedural landscape was defined by reforms under B.P. Blg. 129 and the Interim Rules, which shortened appeal periods and eliminated certain procedural steps to expedite case disposition. However, these laws and rules did not contain an express prohibition against filing motions for extension of time to file a motion for reconsideration. Conflicting judicial interpretations existed, with some prior decisions suggesting such extensions were not authorized, while others, like Gibbs vs. Court of First Instance, had allowed appeals based on excusable neglect without directly ruling the extension motion impermissible. This divergence created uncertainty for litigants and lower courts.

ISSUE

The principal issue for resolution is whether a motion for extension of time to file a motion for new trial or reconsideration of a final order or judgment is permissible under the procedural regime established by B.P. Blg. 129.

RULING

The Court, sitting en banc, granted the motion for reconsideration and dismissed the original petition. The legal logic balances the need for procedural expediency with fairness to parties who relied on prior, unsettled practice. The Court acknowledged that the clear intent of B.P. Blg. 129 and the Interim Rules is to prevent delays and ensure a speedy administration of justice. A motion for reconsideration is not a prerequisite to an appeal, and allowing extensions for such motions contravenes this expediency goal.
However, the Court ruled that applying a strict prohibition retroactively would be unjust. Parties should not be penalized for availing themselves of a procedure (filing for extension) that was not explicitly outlawed and was subject to conflicting judicial pronouncements at the time. Therefore, the Court established a prospective application of the new, strict rule. From one month after this Resolution’s promulgation, motions for extension of time to file a motion for new trial or reconsideration are prohibited in the Metropolitan/Municipal Trial Courts, Regional Trial Courts, and the Intermediate Appellate Court. Such motions may only be filed in the Supreme Court, which retains discretion to grant or deny them. All appeals timely taken based on previously granted extensions were allowed to proceed on their merits. This prospective ruling provides clear guidance to the bench and bar while safeguarding the vested rights of parties in pending cases.