BPI Data Systems Corporation v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns BPI Data Systems Corporation's claim for a refund of P362,617.00, which it alleged was overpaid in creditable taxes withheld in 1987. This claim was initially filed with the Court of Tax Appeals. 2. Procedural History: The Court of Tax Appeals denied BPI's petition for refund on March 3, 1994. BPI filed a motion for reconsideration on April 2, 1994, the last day of the reglementary period. This motion was denied on July 4, 1994. The following day, BPI filed a notice of appeal and sought an extension from the Court of Appeals to file its petition for review. The Court of Appeals denied the petition for review, ruling that the motion for extension was filed one day late. A subsequent motion for reconsideration by BPI was also denied. 3. The Petition: BPI filed a petition for review with the Supreme Court, raising the sole issue of whether a party who files a motion for reconsideration on the last day of the reglementary period must file their petition for review on the same day they receive notice of denial, or if they may file it the following day. The petition argues for the latter interpretation, citing established jurisprudence on the computation of appeal periods.
Issue(s)
Whether the petition for review was filed within the reglementary period. Whether the Court of Appeals erred in denying the petition for review on the ground that the motion for extension was filed one day late.
Ruling
The petition is GRANTED. The questioned resolutions of the Court of Appeals are SET ASIDE, and the appellate court is DIRECTED to reinstate the petition for review.
Ratio Decidendi
On the timeliness of the petition for review: The Court reiterated its pronouncement in Mara, Inc. v. Court of Appeals, which adopted the ruling in Lloren v. De Veyra. The established doctrine is that when a motion for reconsideration is filed on the fifteenth or last day of the reglementary period, that day is excluded in the computation of the period. Consequently, upon receipt of the notice of denial of such motion, the party still has one full day within which to perfect their appeal. This rule is explicitly embodied in Section 3, paragraph 2, of Rule 41 of the Revised Rules of Court. The Court found no reason to deviate from this uniform method of computing periods, especially when the question posed is the finality of a judgment or an order dismissing an appeal. The Court emphasized that the principle applies regardless of whether the appeal is brought via a notice of appeal or a petition for review, as the underlying computation of time remains the same. On the Court of Appeals' denial of the petition: The Court of Appeals erred in ruling that the motion for extension to file the petition for review was filed one day late. Following the established doctrine, the period to file the petition for review should have been reckoned from the day following the receipt of the notice of denial of the motion for reconsideration. Since the motion for reconsideration was filed on the last day of the reglementary period, the day of filing should be excluded. Therefore, the subsequent filing of the motion for extension and the petition for review were within the reglementary period. The Court directed the Court of Appeals to reinstate the petition for review.
Main Doctrine
When a motion for reconsideration is filed on the last day of the reglementary period and is subsequently denied, the period to perfect an appeal is reckoned from the day following the receipt of the notice of denial, consistent with the rule on the computation of periods.