Lacsamana v. Intermediate Appellate Court
REITERATIONFacts
1. The Antecedents: The underlying dispute involved an appeal from a Metropolitan Trial Court decision to the Regional Trial Court of Makati, which then rendered an adverse decision against the petitioners. The petitioners' counsel received a copy of this decision on September 30, 1985. 2. Procedural History: Following the Regional Trial Court's decision, petitioners' counsel sought an extension from the Intermediate Appellate Court (IAC) to file a petition for review. The IAC, citing the case of Habaluyas Enterprises, Inc. vs. Judge Maximo Japzon, denied the motion for extension and declared the case terminated. Petitioners then filed a motion for reconsideration, which was also denied by a division of the IAC. This present petition for certiorari was filed with the Supreme Court to challenge the IAC's decision and resolution. 3. The Petition: The petitioners seek a writ of certiorari to nullify the IAC's decision and resolution. They argue that the IAC erred in applying the Habaluyas ruling, which pertained to motions for reconsideration, not petitions for review. The Supreme Court, in its en banc decision, clarified that motions for extension of time to file a petition for review with the Court of Appeals may be granted, distinguishing this from motions for extension to file motions for new trial or reconsideration, which are generally not allowed except in cases pending with the Supreme Court itself.
Issue(s)
Whether a motion for extension of time to file a petition for review under Section 22 of Batas Pambansa Blg. 129 and Section 22(b) of the Interim Rules may be filed with and granted by the Intermediate Appellate Court. Whether the ruling in Habaluyas Enterprises, Inc. vs. Judge Maximo Japzon applies to motions for extension of time to file a petition for review.
Ruling
The Court ruled in favor of the petitioners, setting aside the decision and resolution of the respondent Court and directing it to admit the petition for review for proper determination. The decision is immediately executory.
Ratio Decidendi
On the issue of whether a motion for extension of time to file a petition for review may be filed with and granted by the Intermediate Appellate Court: The Court held that such a motion may properly be filed with and granted by the Intermediate Appellate Court (now Court of Appeals). The Court clarified that the original ruling in Habaluyas Enterprises, Inc. vs. Judge Maximo Japzon pertained to motions for extension of time to file a motion for reconsideration, not to petitions for review. The Court en banc reversed the original decision in Habaluyas on May 30, 1986, and restated the rules on extensions. Specifically, the Court clarified that while motions for extension to file a motion for new trial or reconsideration are generally not allowed in lower courts and the Intermediate Appellate Court, a motion for extension of time to file a petition for review with the Court of Appeals may be necessary and thus granted. The reason for this is that the period for filing a petition for review is fifteen days, and if a motion for reconsideration is filed and denied by the Regional Trial Court, the remaining period might be too short. On the applicability of the ruling in Habaluyas Enterprises, Inc. vs. Judge Maximo Japzon: The Court distinguished the present case from Habaluyas. The issue in Habaluyas was whether the period for filing a motion for reconsideration could be extended, which the Court originally held could not be done. However, the Supreme Court en banc later reversed this ruling and clarified that such extensions are not allowed in lower courts and the IAC, but are permissible only with the Supreme Court. Crucially, the Habaluyas case did not involve the period for filing a petition for review. The Court emphasized that the original decision in Habaluyas was reversed by the Court en banc on May 30, 1986, and the clarification provided by the en banc decision is controlling. The Court further elaborated on the modes and periods of appeal, distinguishing between ordinary appeals, appeals in special proceedings, appeals by petition for review to the Court of Appeals, appeals from quasi-judicial bodies, and appeals by certiorari to the Supreme Court, clarifying when extensions are permissible for each.
Main Doctrine
A motion for extension of time to file a petition for review under Section 22 of Batas Pambansa Blg. 129 and Section 22(b) of the Interim Rules may properly be filed with and granted by the Intermediate Appellate Court (now Court of Appeals).