Mission v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: Petitioners were defendants in Civil Case No. 481 before the Regional Trial Court (RTC), Branch XVII, Kidapawan, Cotabato. They received an adverse decision on September 15, 1985. Procedural History: On September 24, 1985, petitioners filed an ex-parte motion for extension of time to file a motion for reconsideration. The RTC, in an order dated October 10, 1985, granted them ten days from that date to file their motion for reconsideration. This order was received by petitioners' counsel on October 14, 1985, the same day they filed their motion for reconsideration. The Petition: Private respondent Ricardo Josue opposed the motion for reconsideration, arguing that the ex-parte motion for extension did not suspend the reglementary period for appeal, which had already expired on September 30, 1985. Consequently, the decision sought to be reconsidered had become final and executory. The RTC, on November 13, 1985, reversed its earlier order of October 10, 1985, declaring it null and void, citing this Court's ruling in Habaluyas Enterprises Inc. v. Judge Maximo M. Japson. Petitioners then filed a petition for certiorari and prohibition with the Intermediate Appellate Court (IAC), which dismissed their petition, holding that the RTC Judge did not commit grave abuse of discretion in rectifying his erroneous order. The IAC cited Habaluyas and other cases in support of its ruling.
Issue(s)
Whether the respondent Trial Judge committed grave abuse of discretion in reversing his earlier order granting an extension to file a motion for reconsideration; specifically, whether the Habaluyas rule was correctly applied. Whether the petitioners' motion for extension of time to file a motion for reconsideration was validly filed and granted, considering the grace period established by the en banc resolution of May 30, 1986.
Ruling
The petition is granted. The Order dated November 13, 1985, of the respondent Trial Judge and the Decision of the respondent Court of Appeals promulgated on December 17, 1985, are SET ASIDE. The respondent Trial Judge is directed to consider and resolve the petitioners' motion for reconsideration dated October 11, 1985, in Civil Case No. 481.
Ratio Decidendi
On the issue of the Trial Judge's order and the application of the Habaluyas rule: The Court held that the respondent Trial Judge, in reversing his earlier order, did not act with grave abuse of discretion, as he was rectifying an erroneous order. The Court clarified the application of the Habaluyas rule, which initially established that the 15-day period for appearing or filing a motion for reconsideration cannot be extended. This rule was clarified en banc on May 30, 1986, stating that motions for extension are only allowed in the Supreme Court. The Court gave this rule prospective application, beginning one month from the date of the clarifying resolution. On the issue of the validity of the motion for extension: In the present case, the petitioners' ex-parte motion for extension was filed on September 24, 1985. This date is after the original Habaluyas decision (August 5, 1985) but within the grace period granted by the en banc resolution of May 30, 1986, which extended the grace period until June 30, 1986. Therefore, the petitioners' motion for extension, filed within this grace period, should have been considered. The Court cited Leoncio Bayaca et al. v. Intermediate Appellate Court et al., which recognized this one-month grace period. Consequently, the RTC's order reversing its earlier grant of extension was set aside, and the RTC was directed to resolve the motion for reconsideration.
Main Doctrine
A motion for extension of time to file a motion for reconsideration cannot be granted by the Regional Trial Courts, as such motion may only be filed with the Supreme Court. The strict enforcement of this rule, as clarified in the Habaluyas case, has a prospective application, with a grace period granted for its implementation.