Lonaria v. De Guzman
REITERATIONFacts
1. The Antecedents: Bernardo Lonaria, an agricultural tenant since 1959, leased approximately two hectares of land from Fortunata Santiago for an annual rental of P200.00. In January 1962, Santiago informed Lonaria that the rental would be increased to P250.00, threatening eviction if he refused to pay. 2. Procedural History: Lonaria challenged the rental increase by filing a petition with the Court of Agrarian Relations (CAR), arguing that the legal rental, based on the land's average harvest, should be P216.25 annually as per Republic Act 1199. Santiago countered that the land was first-class and yielded significantly more. On November 26, 1962, the CAR, presided over by Judge Pastor L. de Guzman, ordered Lonaria to pay an additional P25.00 yearly, raising the rental to P225.00, despite Santiago not presenting evidence. Lonaria's subsequent motions for reconsideration were denied by the CAR. 3. The Petition: Lonaria filed a petition for certiorari with the Supreme Court, contending that the CAR's decision was unsupported by evidence and contrary to Republic Act 1199. The core issue before the Supreme Court became whether Lonaria's appeal was perfected within the reglementary period. The Court examined the timeline of Lonaria's filings, including motions for reconsideration and receipt of orders, to determine the commencement of the appeal period, ultimately finding the appeal to be filed beyond the statutory limit.
Issue(s)
Whether the petition for certiorari was filed within the reglementary period. Whether the order of the Court of Agrarian Relations increasing the land rental was supported by evidence and in accordance with law.
Ruling
The petition for certiorari is dismissed for having been filed beyond the reglementary period. The order of the respondent Court of Agrarian Relations dated November 26, 1962, is affirmed.
Ratio Decidendi
On Issue 1 (Reglementary Period): The Supreme Court held that the petition for certiorari was filed beyond the reglementary period. Section 4 of Rule 43 of the Rules of Court mandates that appeals from the Court of Agrarian Relations must be brought within 15 days from notice of the ruling. The Court found that the petitioner had knowledge of the order on November 26, 1962, when it was dictated in open court, and further evidenced this knowledge by filing a first motion for reconsideration on November 28, 1962. By filing this motion, the petitioner waived his right to have the appeal period counted from the receipt of a copy of the order. The period for appeal should have commenced from the filing of the first motion for reconsideration, November 28, 1962. Although the denial of this motion was received on January 4, 1963, suspending the period, the petitioner's second motion for reconsideration, filed on January 22, 1963, was considered pro forma and did not interrupt the appeal period. By January 22, 1963, 18 days had already lapsed since January 4, 1963, exceeding the 15-day period for appeal. Therefore, the appeal was not perfected on time. On Issue 2 (Merits of the CAR Order): The Court deemed it unnecessary to discuss the merits of the case, including whether the CAR's order was supported by evidence and in accordance with law, due to the procedural defect of the appeal being filed out of time. The principle of cessante ratione legis, cessat et ipsa lex (where the reason of the law ceases, the law itself ceases) was invoked to explain why the appeal period should not be counted from the receipt of the order on January 18, 1963, as the petitioner's prior actions (filing a motion for reconsideration) had already fulfilled the purposes of the rule regarding notice.
Main Doctrine
The Supreme Court reiterated that the period for perfecting an appeal is jurisdictional and must be strictly observed. The filing of a motion for reconsideration, if pro forma or based on grounds already raised, does not suspend the running of the reglementary period for appeal. Consequently, an appeal filed beyond the prescribed period, even with subsequent motions, will be dismissed for having been filed out of time.