GR L 74824; (September, 1986) (Digest)
G.R. No. 74824 . September 15, 1986.
LEONCIO BAYACA, SIMEON BAYACA, JUDITH BAYACA, and RAMOS VALDEZ, petitioners, vs. THE HONORABLE INTERMEDIATE APPELLATE COURT, PERFECTO TEBANGIN and ROSALINA MALLARI, respondents.
FACTS
Petitioners received a copy of the respondent Intermediate Appellate Court’s decision on February 13, 1986, giving them until February 28, 1986, to file a motion for reconsideration. On February 27, 1986, their new counsel filed an “Urgent ex-parte Motion for Extension of Time to File Motion for Reconsideration,” seeking a fifteen-day extension until March 15, 1986. Petitioners subsequently filed their actual Motion for Reconsideration on March 12, 1986. Private respondents opposed both the extension and the motion for reconsideration.
On May 26, 1986, the respondent Court denied the motion for extension, citing the Supreme Court’s ruling in Habaluyas Enterprises, Inc. vs. Judge Japson (August 5, 1985), which held that the period for filing a motion for reconsideration is non-extendible. The Supreme Court initially denied the petitioners’ subsequent Petition for Certiorari and Prohibition, prompting the instant Motion for Reconsideration.
ISSUE
Did the respondent Intermediate Appellate Court commit grave abuse of discretion in denying the motion for extension of time to file a motion for reconsideration based on the original Habaluyas ruling?
RULING
No, the denial was initially correct but was subsequently superseded by a clarifying resolution. The Supreme Court granted the petitioners’ Motion for Reconsideration. The legal logic hinges on the application of a grace period established by the Court’s clarificatory resolution in the Habaluyas case promulgated on May 30, 1986. While the original Habaluyas ruling (August 5, 1985) strictly prohibited the filing of motions for extension of time to file motions for new trial or reconsideration in lower courts, the clarificatory resolution provided a one-month grace period from its promulgation—until June 30, 1986—before the strict prohibition would be enforced.
Consequently, motions for extension filed before June 30, 1986, like the petitioners’ motion filed on February 27, 1986, fell within this grace period and could still be allowed. The respondent Court’s May 26, 1986 Resolution, issued before this clarification and relying on the original strict rule, was therefore set aside. The Supreme Court directed the respondent Court to grant the extension and resolve the pending Motion for Reconsideration on its merits.