Gonzaga vs. David

The "last working day" contemplated in Section 8(I) of Act 3992 does not necessarily mean the last working day of the Motor Vehicles Office; where payment is made by mail under Section 6(b), the date of cancellation of postage stamps is considered the date of application, and the law impliedly permits remittance within that last day of August that the Post Office may still effect cancellation. Furthermore, where the last day for doing an act falls on a holiday, the act may be done on the next succeeding business day pursuant to Section 31 of the Revised Administrative Code.

Mariano S. Gonzaga was the owner of a cargo truck and a passenger bus registered with the Motor Vehicles Office. Under Act 3992, otherwise known as the Revised Motor Vehicle Law, registration fees for trucks could be paid in two equal installments, with the second installment due on or before the last working day of August. The case involved the interpretation of this statutory deadline in relation to payments made by mail and the effect of holidays and the 40-Hour Week Law on the computation of the deadline.

In February 1957, Mariano Gonzaga, as owner, registered a cargo truck and a passenger bus with the Motor Vehicles Office, paying the first installment for registration fees due on said vehicles for 1957. To cover the second installment for registration fees, Gonzaga remitted to the Provincial Treasurer of Cagayan, by registered mail, P500.00, under postal money orders Nos. 18553, 18554, and 18555, purchased from and issued by the Post Office of Camalaniugan, Cagayan. The postal cancellation mark on the envelope containing the remittance bears the date August 31, 1957, as does the postal cancellation mark on the face of the money orders.

The Registrar of the Motor Vehicles Office of Cagayan ruled that pursuant to Section 8(1) of Act 3992, the second installment for registration fees was payable on or before the last working day of August; that the last working day of August 1957 was Friday, August 30, 1957; and that consequently, the remittance bearing postal cancellation mark dated August 31, 1957 was made beyond the time fixed by law. Accordingly, said official sought to impose a 50% delinquency penalty, or otherwise, threatened to confiscate the certificate of registration for the two trucks.

Gonzaga brought this action in the Court of First Instance, which, upon a stipulation of facts, rendered judgment declaring that the payment made with the postal money orders was made within the period fixed by law, and ordered the respondent to abstain from confiscating the certificates of registration. The respondent appealed, invoking Republic Act No. 1880, otherwise known as the "40-Hour Week Law," pursuant to which government offices are to hold office from Monday to Friday only, unless one of those expressly exempted therefrom, to support its contention that August 30, and not August 31, was the last working day of August 1957.

• Timeliness of Payment: Petitioner-appellee Gonzaga argued that his remittance was made within the period fixed by law, relying on Section 6(b) of Act 3992 which provides that the date of cancellation of postage stamps of envelopes containing money orders shall be considered as the date of application.

• Last Working Day: Respondent-appellant argued that pursuant to Republic Act No. 1880, the "40-Hour Week Law," government offices hold office from Monday to Friday only, and therefore the last working day of August 1957 was Friday, August 30, 1957, making the remittance bearing postal cancellation dated August 31, 1957 late.
• Special Public Holiday: Respondent-appellant also invoked the fact that August 31, 1957 was declared a special public holiday by Proclamation No. 437, which it argued made the preceding day, August 30, the last day for paying registration fees without penalty.

• Timeliness of Remittance: Whether the remittance of petitioner-appellee covering the second installment of registration fees for 1957, made by registered mail with postal cancellation dated August 31, 1957, was within the time fixed by law.

• Timeliness of Remittance: Yes. The remittance was made within the period fixed by law. Under Section 6(b) of Act 3992, the date of cancellation of the postage stamps of the envelope containing the remittance is considered the date of application, and the law impliedly permits remittance within that last day of August that the Post Office may still effect cancellation. Moreover, since August 31, 1957 was declared a special public holiday, Section 31 of the Revised Administrative Code allowed the act to be done on the next succeeding business day.

• Timeliness of Remittance: The Court held that the fact that the Motor Vehicles Office in Tuguegarao, Cagayan had no office on Saturday, August 31, 1957, pursuant to Republic Act 1880, is immaterial. The last working day contemplated in Section 8(I) of Act 3992 as amended should not necessarily mean the last working day for the Motor Vehicles Office. Under Section 6(b) of said Act, providing for payment of registration fees by mail, the date of cancellation of the postage stamps of the envelope containing the remittance is considered the date of application. Consequently, where the manner of payment falls under said Section 6(b), the law, in recognizing the date of cancellation as the date of application, impliedly permits of a remittance or payment within that last day of August that the Post Office may still effect cancellation; and the remittance, in fact, bears a postal cancellation dated August 31, 1957. Moreover, it was not pretended by respondent-appellant that the Post Office ceased or has ceased to transact business and discharge its functions on Saturdays by reason alone of Republic Act No. 1880.

The Court further held that the fact that August 31, 1957 was declared a special public holiday by Proclamation No. 437 did not have the effect of making the preceding day, August 30, the last day for paying registration fees without penalty. On the contrary, Section 31 of the Revised Administrative Code provides that where the day, or the last day, for doing any act required or permitted by law falls on a holiday, the act may be done the next succeeding business day. The Court cited the ruling in Calano vs. Cruz, 91 Phil., 247, which applied Section 31 of the Revised Administrative Code to a similar situation involving a special public holiday, and found the ruling "on all fours" with the issue before it.

• Date of Cancellation as Date of Application — Under Section 6(b) of Act 3992, where payment of registration fees is made by mail, the date of cancellation of the postage stamps of the envelope containing the remittance is considered the date of application. The Court applied this doctrine to hold that the remittance bearing postal cancellation dated August 31, 1957 was made within the period fixed by law, as the law impliedly permits remittance within that last day of August that the Post Office may still effect cancellation.

• Pretermission of Holiday — Under Section 31 of the Revised Administrative Code, where the day, or the last day, for doing any act required or permitted by law falls on a holiday, the act may be done the next succeeding business day. The Court applied this doctrine to hold that the declaration of August 31, 1957 as a special public holiday did not make August 30 the last day for paying registration fees without penalty.

• "The last working day contemplated in Sec. 8(I) of Act 3992 as amended should not necessarily mean the last working day for Motor Vehicle Office. Under Sec. 6(b) of said Act, providing for payment of registration fees by mail, the date of cancellation of the postage stamps of the envelope containing the remittance is considered the date of application." — This passage articulates the core ratio decidendi: the statutory deadline must be interpreted in light of the mode of payment permitted by law, and the date of postal cancellation controls for mail payments.

• "Consequently, where the manner of payment falls under said Section 6(b), the law, in recognizing the date of cancellation as the date of application, impliedly permits of a remittance or payment within that last day of August that the Post Office may still effect cancellation." — This passage explains the implied legislative intent behind Section 6(b) and why the Post Office's operational schedule, rather than the Motor Vehicles Office's, governs the timeliness of mail payments.

• "On the contrary, Section 31 of the Revised Administrative Code provides — 'Where the day, or the last day, for doing any act required or permitted by law falls on a holiday, the act may be done the next succeeding business day.'" — This passage states the controlling statutory rule for computing deadlines that fall on holidays, which the Court applied to the special public holiday declared for August 31, 1957.

• Calano vs. Cruz, 91 Phil., 247 — Controlling precedent, followed. The Court applied the ruling in this case, which held that Section 31 of the Revised Administrative Code applies even where the last day for doing an act falls on a special public holiday, allowing the act to be done on the next succeeding business day. The Court found this ruling "on all fours" with the issue before it.

• Section 8(I), Act 3992 (Revised Motor Vehicle Law) — Provides that registration fees for trucks may be payable in two equal installments, the first to be paid on or before the last working day of February, and the second to be paid on or before the last working day of August. The Court interpreted this provision to determine the deadline for the second installment payment.

• Section 6(b), Act 3992 (Revised Motor Vehicle Law) — Provides that the date of cancellation of the postage stamps of envelopes containing money orders, checks, or cash shall be considered as the date of application. The Court applied this provision to hold that the postal cancellation date of August 31, 1957 was the operative date of payment.

• Section 31, Revised Administrative Code — Provides that where the day, or the last day, for doing any act required or permitted by law falls on a holiday, the act may be done the next succeeding business day. The Court applied this provision to the special public holiday declared for August 31, 1957.

• Republic Act No. 1880 (40-Hour Week Law) — Pursuant to this law, government offices are to hold office from Monday to Friday only, unless one of those expressly exempted therefrom. The Court held that this law was immaterial because the last working day contemplated in Section 8(I) of Act 3992 should not necessarily mean the last working day for the Motor Vehicles Office.

Bengzon, Padilla, Bautista Angelo, Labrador, Concepcion, Barrera, Gutierrez David, Paredes, and Dizon, JJ., concurred.