G.R. No. L-73669 October 28, 1986
FEDERICO MISSION, APELINA NICOR and DEMOCRITO FORDAN, petitioners, vs. THE HONORABLE INTERMEDIATE APPELLATE COURT, HONORABLE BENJAMIN M. ESTANOL, and RICARDO JOSUE, respondents.

FACTS

Petitioners were defendants in Civil Case No. 481 before the Regional Trial Court (RTC) of Kidapawan, Cotabato. They received an adverse decision on September 15, 1985. On September 24, 1985, they filed an “Ex-parte Motion for Extension of Time to File Motion for Reconsideration,” seeking a 15-day extension from September 30, 1985. The RTC Judge granted a 10-day extension via an Order dated October 10, 1985, which petitioners received on October 14, 1985—the same day they filed their motion for reconsideration. Private respondent Ricardo Josue opposed this, arguing the ex-parte motion did not suspend the reglementary period, which expired on September 30, 1985, rendering the decision final and executory by October 14.
The RTC Judge, citing the Supreme Court’s ruling in Habaluyas Enterprises, Inc. v. Japson (promulgated August 5, 1985), which held that the 15-day period for filing a motion for reconsideration cannot be extended, reversed his own October 10 Order on November 13, 1985, declaring it null and void. Petitioners then filed a petition for certiorari and prohibition with the Intermediate Appellate Court (IAC), which dismissed it on December 17, 1985, upholding the trial judge’s corrective order as conforming with law and jurisprudence.

ISSUE

Whether the petitioners’ motion for extension of time to file a motion for reconsideration, filed on September 24, 1985, should be allowed despite the rule established in the original Habaluyas decision.

RULING

The Supreme Court granted the petition, setting aside the orders of the lower courts. The legal logic centers on the prospective application of the strict rule from Habaluyas. While the original Habaluyas decision on August 5, 1985, prohibited extensions for filing motions for reconsideration in lower courts, the Court en banc issued a clarifying resolution on May 30, 1986. This resolution mandated that the strict rule would be enforced only “beginning one month after” its promulgation, effectively granting a grace period until June 30, 1986. The Court, in the interest of justice, intended to mitigate the rule’s impact by applying it prospectively.
In this case, petitioners filed their ex-parte motion for extension on September 24, 1985. This date falls after the original Habaluyas ruling but well within the grace period established by the en banc resolution. Following the precedent in Bayaca v. Intermediate Appellate Court, where a motion filed in February 1986 was allowed, the Court held that motions filed within the grace period (i.e., before June 30, 1986) were permissible. Consequently, the trial judge erred in nullifying his extension order based strictly on the original Habaluyas ruling without considering the operative grace period. The RTC was directed to consider and resolve the petitioners’ motion for reconsideration.