Soque v. Court of Appeals
REITERATIONFacts
1. The Antecedents: This case concerns an agrarian dispute between Rodolfo B. Soque, the landowner, and Sulpicio Libuton. The specific details of the underlying dispute are not elaborated upon in this resolution, but it was adjudicated by the Court of Appeals. 2. Procedural History: The Court of Appeals rendered a decision in an agrarian case, CA G.R. No. SP-11252-CAR, on January 13, 1981, which was served on Soque's counsel on January 22, 1981. Soque filed a motion for reconsideration on February 9, 1981, which the Court of Appeals did not act upon, citing Presidential Decree No. 946, Section 18, which prohibits motions for rehearing or reconsideration in agrarian cases decided by the Court of Appeals. Subsequently, on March 17, 1981, the Clerk of Court of the Court of Appeals erroneously entered judgment, assuming the decision became final on February 7, 1981, and the record was remanded to the Agrarian Court on March 20, 1981. 3. The Petition: Rodolfo B. Soque filed an urgent motion for an extension of time to file a petition for review on certiorari with the Supreme Court on March 19, 1981, alleging receipt of the Court of Appeals' resolution on March 10, 1981. The Supreme Court initially granted a thirty-day extension on June 5, 1981, through oversight, and Soque's petition was mailed on April 14, 1981. However, the Supreme Court determined that the petition was filed out of time, as the thirty-day period for appeal under Presidential Decree No. 946, Section 18, is non-extendible and the judgment became final on February 21, 1981. The resolution granting the extension was set aside, and the petition was dismissed.
Issue(s)
Whether the entry of judgment by the Court of Appeals was erroneous. Whether the petition for review on certiorari was filed out of time.
Ruling
The petition is dismissed. The entry of judgment was erroneous, and the petition was filed out of time. The resolution granting an extension of time is set aside.
Ratio Decidendi
On the erroneous entry of judgment: The Court held that the entry of judgment on March 17, 1981, was erroneous because the decision did not become final on February 7, 1981. Instead, it became final on February 22, 1981, which is thirty days after notice to Soque's counsel. Section 18 of Presidential Decree No. 946 grants a non-extendible period of thirty days from notice of the decision within which to file an appeal to the Supreme Court by means of a petition for review on certiorari. In ordinary cases, this period is fifteen days, making the judgment final on the sixteenth day. However, in agrarian cases, the Court of Appeals should enter judgment on the thirty-first day or thereafter, signifying the expiration of the thirty-day appeal period without an appeal being filed. On the petition being filed out of time: The Court ruled that the petition was filed out of time. The thirty-day period for appeal, as provided by Section 18 of Presidential Decree No. 946, is non-extendible. Therefore, the petition should have been filed within thirty days from January 22, 1981, the date Soque was served with a copy of the decision, making the deadline February 21, 1981. The extension of thirty days granted to Soque by the Supreme Court's resolution of June 5, 1981, was granted through oversight and is hereby set aside, as Soque was not entitled to such an extension. The Court emphasized that the non-extendible nature of the thirty-day period is peremptory and mandatory, intended to avoid delays in the disposition of agrarian cases, as underscored by the provision for a non-extendible fifteen-day period for forwarding records to the Court of Appeals.
Main Doctrine
The thirty-day period for appeal in agrarian cases, as provided under Section 18 of Presidential Decree No. 946, is non-extendible and mandatory, and the Court of Appeals should enter judgment only after the expiration of this period if no appeal is filed.