Daday v. De Guzman
REITERATIONFacts
The Antecedents: Saturnina Pabilian instituted a tenancy litigation against Carmelino Daday and others. Procedural History: The Court of Agrarian Relations rendered a decision in favor of Saturnina Pabilian. Petitioners received a copy of this decision on May 28, 1959. They filed a motion to set aside the decision on June 11, 1959. This motion was denied, and they were notified of the denial on September 2, 1959. The Petition: Petitioners filed a petition for review with the Supreme Court on September 4, 1959. The primary issue raised by the respondents concerns the timeliness of this petition, alleging it was filed beyond the fifteen-day period prescribed by law.
Issue(s)
Whether the petition for review was filed within the reglementary period. Whether the failure to file the petition within the reglementary period is fatal to the case.
Ruling
The petition for review was filed beyond the period prescribed by law. Therefore, it is dismissed.
Ratio Decidendi
On Whether the petition for review was filed within the reglementary period: The respondents correctly computed the period for filing the petition. Petitioners received the decision on May 28, 1959. Their motion to set aside was filed on June 11, 1959, which is within the 14-day period from May 28 to June 11. However, the denial of their motion was received on September 2, 1959. The petition for review was filed on September 4, 1959. This means that the period from September 2 to September 4 constitutes 2 days. The total period from the receipt of the decision to the filing of the petition, considering the motion to set aside, amounts to 16 days (14 days + 2 days). This exceeds the fifteen-day period allowed by law. The attorney for the petitioners attempted to claim receipt of the decision on May 29, 1959, but this was contradicted by the records of the Agrarian Court, which showed a notation of receipt by the attorney on May 28, 1959. On Whether the failure to file the petition within the reglementary period is fatal to the case: The Supreme Court affirmed that failure to appeal or to petition within the time prescribed by law is fatal. This procedural defect deprives the appellate court of jurisdiction to entertain the case. Consequently, the judgment sought to be reviewed becomes final and executory. The Court found it unnecessary to discuss other procedural issues raised, such as the failure to file a notice of appeal with the Agrarian Court, because the petition was already dismissed on the ground of tardiness. The dismissal is based on the principle that procedural rules, especially those concerning reglementary periods, are essential for the orderly administration of justice and the finality of judgments.
Main Doctrine
The Supreme Court reiterated the fundamental procedural rule that the failure to file an appeal or petition within the statutory period is fatal to the cause of the party concerned. Such failure renders the judgment final and executory, and the appellate court loses jurisdiction to entertain the appeal or petition. This principle emphasizes the importance of strict adherence to reglementary periods to ensure the stability and finality of judicial decisions.