Leynes v. Superales
REITERATIONFacts
The Antecedents: This case concerns a dispute over land possession initiated by respondents Spouses Gualberto and Rene Cabahug-Superales against petitioners Spouses Ruben and Myrna Leynes. The Spouses Superales alleged that the Spouses Leynes unlawfully encroached upon and occupied approximately 76 square meters of their titled residential lot through force, stealth, and strategy, constructing a comfort room extension without proper permits. The Spouses Superales claimed this encroachment reduced their lot's area and sought restitution of possession, demolition of the unauthorized construction, payment of monthly rentals for the occupied portion, reimbursement for survey costs, and attorney's fees. Procedural History: The Spouses Superales filed a complaint for forcible entry and damages with the Municipal Circuit Trial Court (MCTC), which served summons on the Spouses Leynes. The Spouses Leynes filed their Answer with Counterclaim belatedly, on May 22, 2000, after the ten-day period prescribed by the Rules on Summary Procedure had expired on Saturday, May 20, 2000. The MCTC denied their motion to admit the belated answer and rendered an ex parte judgment in favor of the Spouses Superales. The Spouses Leynes appealed to the Regional Trial Court (RTC), which affirmed the MCTC's decision with a modification regarding the monthly rental amount. The Spouses Leynes' subsequent motion for reconsideration was denied by the RTC. They then filed a Petition for Certiorari with the Court of Appeals (CA), which dismissed the petition for being the wrong remedy and for failing to state material dates. The CA later denied their motion for reconsideration. The Spouses Leynes then filed the instant Petition for Certiorari with the Supreme Court. The Petition: The Spouses Leynes filed a Petition for Certiorari under Rule 65 of the Rules of Court, assailing the resolutions of the Court of Appeals that dismissed their earlier petition. They argue that the CA committed grave abuse of discretion by dismissing their petition on technicalities without considering the merits of their case. Specifically, they contend that the MCTC and RTC erred in denying their belatedly filed answer, asserting that the ten-day period for filing should have been extended to the next working day, Monday, May 22, 2000, as the deadline fell on a Saturday. They also argue that their complaint for forcible entry was filed beyond the one-year prescriptive period. The Supreme Court, in its discretion, granted the petition, finding that the Spouses Leynes were unjustly declared in default and that remanding the case for admission of their answer would serve substantial justice.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion in dismissing the spouses Leynes' Petition for Certiorari. Whether the MCTC and RTC committed grave abuse of discretion in denying the spouses Leynes' Motion to Admit Belatedly Filed Answer. Whether the spouses Superales' Complaint for forcible entry was filed within the one-year prescriptive period.
Ruling
The Supreme Court GRANTED the Petition. The ex parte Judgment dated May 29, 2000, of the MCTC is ANNULLED and SET ASIDE. The case is REMANDED to the MCTC, which is DIRECTED to admit the Answer with Counterclaim of the spouses Ruben and Myrna Leynes and conduct further proceedings.
Ratio Decidendi
On the propriety of the Petition for Certiorari: The Supreme Court acknowledged that while a petition for certiorari is generally not the proper remedy when an appeal is available, it may be given due course in exceptional circumstances to prevent a miscarriage of justice. In this case, the rigid application of the rule would result in the spouses Leynes being unjustly deprived of their day in court due to a technicality. The Court found that the spouses Leynes were unjustly declared in default and denied the opportunity to present their defenses. Therefore, the Court accepted the petition in the interest of substantial justice and equity, despite the procedural defect. On the timeliness of the Answer: The Supreme Court disagreed with the MCTC and RTC's ruling that the spouses Leynes' answer was filed out of time. The Court clarified that under Rule 22, Section 1 of the Rules of Court, if the last day of the period for filing an answer falls on a Saturday, Sunday, or legal holiday, the period is extended to the next working day. Since the spouses Leynes were served summons on May 10, 2000, the 10-day period ended on May 20, 2000, a Saturday. They filed their answer on May 22, 2000, a Monday, which was within the reglementary period. The Court emphasized that Administrative Circular No. 2-99, which mandated court personnel to be on duty on Saturdays, did not amend the Rules of Court regarding the computation of time. Furthermore, the circular was primarily for urgent matters like bail petitions, and the filing of an answer in a forcible entry case was not considered such an urgent matter. The Court also noted that the answer should have been filed with the MCTC Branch, not the Office of the Clerk of Court. On the prescriptive period for forcible entry: The Supreme Court found no merit in the spouses Leynes' argument that the forcible entry complaint had prescribed. The Court reiterated that under Rule 70, Section 1 of the Rules of Court, a forcible entry action must be brought within one year from the date of unlawful deprivation or withholding of possession. The spouses Superales alleged that the encroachment occurred in February 2000 and they filed their complaint in May 2000, which is well within the one-year period. However, the Court noted that the spouses Leynes' averments regarding the actual construction dates in 1985 and 1987 involved factual matters that could not be resolved by the Supreme Court, as it is not a trier of facts. Due to the ex parte judgment and the denial of their answer, the spouses Leynes were not given the opportunity to present evidence on these factual claims. Therefore, the case was remanded to the MCTC for further proceedings to allow the spouses Leynes to present their evidence.
Main Doctrine
The Supreme Court held that the computation of the reglementary period for filing an answer under the Rules on Summary Procedure, when the last day falls on a Saturday, should be extended to the next working day, consistent with Rule 22, Section 1 of the Rules of Court. Administrative Circulars governing court operations on Saturdays do not amend the Rules of Court regarding computation of periods.