Ditching v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from an ejectment case filed by Cecile San Juan Ditching and Zonette San Juan Bacani against Adriano Motas and Vidal Batalla concerning a lot in Calamba, Laguna. Petitioners claimed ownership and sought possession, asserting that respondent Motas constructed his house on the property without consent and refused to vacate after demand. Respondent Motas, however, contended that a tenancy agreement existed with the petitioners' predecessor-in-interest, Dr. Eduardo San Juan, since 1972, and that the lot where his house was situated was part of this leasehold, rendering the ejectment suit a tenancy case outside the Municipal Trial Court's jurisdiction. 2. Procedural History: The Municipal Trial Court dismissed the ejectment case, finding a tenancy relationship and lack of jurisdiction. This decision was affirmed by the Regional Trial Court. However, the RTC later reversed its own decision upon reconsideration, ordering the defendants to vacate. Subsequently, another RTC judge, acting on a motion for reconsideration by respondent Motas, set aside the previous order and reinstated the MTC's dismissal, ruling that the RTC had erred in conducting further hearings and admitting new evidence. Petitioners then filed a petition for review with the Court of Appeals. 3. The Petition: Petitioners filed a petition for review on certiorari under Rule 45 of the Rules of Court with the Court of Appeals, assailing the RTC's final order. They sought an extension of fifteen days to file the petition, which was granted by the CA conditioned upon the timeliness of the motion. The CA, however, dismissed the petition, finding that the motion for extension was filed twenty days after receipt of the adverse order, thus exceeding the allowable period and rendering the judgment final and executory. The CA reasoned that the motion for extension itself was filed late, and therefore, it lacked jurisdiction to entertain the petition. Petitioners now seek review of the CA's dismissal, arguing that the dismissal on technicality was erroneous and that the merits of their case should have been considered.
Issue(s)
Whether the Court of Appeals correctly dismissed the petition for review on the ground that the motion for extension of time to file the petition was filed late. Whether respondent Adriano Motas is a tenant of the parcel of land covered by TCT No. 57923. Whether the dismissal of the case on sheer technicality by the Court of Appeals, notwithstanding its merit, is valid.
Ruling
The petition is denied. The Court of Appeals did not commit any reversible error in dismissing the petition for review.
Ratio Decidendi
On the issue of the timeliness of the petition for review and the motion for extension: The Court reiterated the ruling in Lacsamana vs. Second Special Cases Division of the Intermediate Appellate Court that a motion for extension of time to file a petition for review must be filed within the reglementary period of appeal. In this case, petitioners received the adverse RTC order on March 17, 1992. They filed a motion for reconsideration on March 27, 1992, and received the denial of their motion on April 3, 1992. The reglementary period to file a petition for review would have expired on April 18, 1992. However, petitioners filed their motion for extension of time on April 13, 1992, which was within the reglementary period. The CA's computation that twenty (20) days had elapsed from receipt of the order to the filing of the motion for extension was based on a miscalculation of the dates. The CA's resolution granting the extension was conditioned upon its timeliness, and the petition was filed within the granted extension. The CA's dismissal was based on its erroneous finding that the motion for extension was filed late. The Court found that the motion for extension was timely filed. On the issue of whether respondent Adriano Motas is a tenant: The Court held that this is a factual issue, and it is a well-settled rule that findings of fact of the trial court are entitled to great weight and are not disturbed on appeal except for cogent reasons, which petitioners failed to show. The Court noted that the RTC affirmed the MTC's finding of a tenancy relationship. Therefore, the Court did not pass upon this issue, as it would violate the rule on factual findings. On the issue of dismissal on sheer technicality: The Court emphasized that the perfection of an appeal within the statutory period is a jurisdictional requirement. Failure to comply with this rule renders the judgment final and executory. The Court reiterated that a lawyer has the responsibility to monitor and keep track of the period for filing an appeal, and an erroneous computation by counsel is not an excusable error. The Court stressed that the rules on periods for filing appeals must be observed religiously as they are indispensable interdictions against needless delays and for the orderly discharge of judicial business. The Court found no reason to relax the rule in this case, as the delay was inexcusable. The Court also clarified that the CA's initial statement that the petition was prima facie meritorious did not preclude it from dismissing the petition for being filed out of time, as the allowance of the appeal did not carry with it the assumption that it was timely filed.
Main Doctrine
A motion for extension of time to file a petition for review must be filed within the reglementary period to appeal; otherwise, the judgment sought to be appealed becomes final and executory, and the appellate court loses jurisdiction to entertain the petition.