Luz vs. National Amnesty Commission

A.M. No. 00-2-14-SC, which provides that any extension of time to file a required pleading should be counted from the expiration of the original period regardless of whether the due date falls on a Saturday, Sunday, or legal holiday, is the controlling rule on computation of extensions; however, in exceptional circumstances where counsel has relied in good faith on prior jurisprudence and the petition has already been filed before the extension is resolved, a liberal interpretation of the rules may be applied to serve substantial justice.

Petitioner Jaime Beltran Luz had been charged with illegal possession of firearms under Presidential Decree No. 1866 before the Regional Trial Court of Makati City. He subsequently applied for amnesty with the Local Amnesty Board for Metro Manila, which denied his application. The National Amnesty Commission affirmed the denial. Under Rule III, Section 4 of NAC Administrative Order No. 2, Series of 1999, a party aggrieved by the NAC's resolution may file a petition for review with the Court of Appeals within fifteen days from receipt of the resolution.

On July 18, 1988, Jaime Beltran Luz was charged with violation of Presidential Decree No. 1866 (illegal possession of firearms) before the Regional Trial Court of Makati City, docketed as Criminal Case No. 427. On March 22, 2000, Luz filed an application for amnesty with the Local Amnesty Board for Metro Manila. The board denied the application in due course. On August 26, 2002, the National Amnesty Commission issued a Resolution affirming the Local Amnesty Board's denial. Luz's motion for reconsideration was denied by the NAC per its Resolution dated November 13, 2002, a copy of which he received on November 22, 2002.

Under Rule III, Section 4 of NAC Administrative Order No. 2, Series of 1999, Luz had until December 7, 2002 — a Saturday — within which to file a petition for review with the Court of Appeals. On December 9, 2002, he filed a motion in the appellate court for a fifteen-day extension from December 9, or until December 24, 2002, alleging that he had just engaged the services of counsel who needed additional time to study the case and draft the petition. However, Luz failed to file the petition within that period. December 24 and 25, 2002 were both declared national holidays. On December 26, 2002, Luz filed a second motion for a fifteen-day extension from December 26, or until January 10, 2003. He filed his petition for review with the Court of Appeals on January 10, 2003.

On January 13, 2003, the CA issued a Resolution granting Luz's first motion for extension, reckoning the fifteen-day period from December 7, 2002 — the original expiration date — rather than from December 9, 2002 as prayed for, in accordance with A.M. No. 00-2-14-SC. On February 20, 2003, the CA denied Luz's second motion for extension as filed out of time. Luz moved for reconsideration, arguing that since the last day to file his petition was Saturday, December 7, 2002, and the next day, December 8, 2002, was a Sunday, the last day for filing should have been December 9, 2002, making his motion for extension timely filed. On August 19, 2003, the CA denied the motion, relying on A.M. No. 00-2-14-SC, which provides that any extension of time should be counted from the expiration of the original period regardless of whether the due date falls on a Saturday, Sunday, or legal holiday.

• Contrary to Rule 22, Section 1: Petitioner asserted that the CA resolutions are contrary to Section 1, Rule 22 of the Rules of Court and the ruling in Labad vs. University of Southeastern Philippines, which was promulgated after the Court issued A.M. No. 00-2-14-SC.
• Limited Application of A.M. No. 00-2-14-SC: Petitioner contended that the rule in A.M. No. 00-2-14-SC should apply only where a motion for extension does not specifically state the reckoning date of the extension prayed for, such that the extension would be reckoned from the last day of the period even if it was a Saturday, Sunday, or legal holiday.
• Liberal Interpretation in the Interest of Justice: Petitioner argued that even assuming his second motion for extension was filed out of time, the CA should have admitted his petition for review in the interest of justice.

• A.M. No. 00-2-14-SC Remains Valid: Respondent averred that the ruling in Labad vs. University of Southeastern Philippines has not voided, overturned, nor vacated A.M. No. 00-2-14-SC, and as such the latter should prevail.
• No Presumption of Grant: Respondent asserted that petitioner should not have presumed that the CA would grant him an extension until December 24, 2002 within which to file his petition for review.

• Timeliness of Second Motion for Extension: Whether the petitioner timely filed his second motion for extension of time to file his petition for review with the Court of Appeals.

• Timeliness of Second Motion for Extension: No, as a strict matter of procedural rule, but yes as applied under the circumstances. The second motion was technically filed out of time under A.M. No. 00-2-14-SC, which mandates that extensions be counted from the expiration of the original period regardless of whether the due date falls on a Saturday, Sunday, or legal holiday. However, the petition was granted on grounds of substantial justice and liberal interpretation of the rules.

• Timeliness of Second Motion for Extension: Section 1, Rule 22 of the 1997 Rules of Civil Procedure provides that if the last day of a period falls on a Saturday, Sunday, or legal holiday, the time shall not run until the next working day. However, the Court clarified this provision through A.M. No. 00-2-14-SC, which declares that Section 1, Rule 22 speaks only of "the last day of the period," so that when a party seeks and is granted an extension, the due date ceases to be the last day and the provision no longer applies; any extension must be counted from the expiration of the original period regardless of whether that date is a Saturday, Sunday, or legal holiday. The CA therefore correctly applied A.M. No. 00-2-14-SC in reckoning the first extension from December 7, 2002, and had it reckoned from December 9, 2002 as prayed, it would have acted with grave abuse of discretion. Petitioner's reliance on Labad vs. University of Southeastern Philippines and Moskowsky vs. Court of Appeals was misplaced because A.M. No. 00-2-14-SC did not yet exist when Moskowsky was decided, and Capulong vs. Workmen's Insurance Co., Inc. was anchored on an RTC order granting extension without indicating when it would commence — unlike here, where the CA specifically stated the extension was reckoned from December 7, 2002. Nevertheless, the Court applied a liberal interpretation of A.M. No. 00-2-14-SC in light of the peculiar factual milieu: petitioner's counsel relied in good faith on the Moskowsky ruling, and the petition for review was filed on January 10, 2003, before the CA even granted the first motion for extension on January 13, 2003. Citing Labad, the Court emphasized that the right to appeal, while statutory, is an essential part of the judicial system, and courts should proceed with caution so as not to deprive a party of that right, ensuring every party-litigant has the amplest opportunity for the proper and just disposition of his cause, freed from the constraints of technicalities.

• A.M. No. 00-2-14-SC (Clarification of Section 1, Rule 22) — Section 1, Rule 22 of the Rules of Court, which extends the period to the next working day when the last day falls on a Saturday, Sunday, or legal holiday, applies only to "the last day of the period." When a party seeks an extension and it is granted, the due date ceases to be the last day, and the provision no longer applies. Any extension of time to file the required pleading must be counted from the expiration of the original period regardless of whether the due date is a Saturday, Sunday, or legal holiday. The Court applied this rule but relaxed its strict application in this case on grounds of substantial justice and good-faith reliance on prior jurisprudence.

• Liberal Interpretation of Procedural Rules in the Interest of Substantial Justice — While the right to appeal is a statutory, not a natural, right, it is an essential part of the judicial system, and courts should proceed with caution so as not to deprive a party of the right to appeal, ensuring every party-litigant has the amplest opportunity for the proper and just disposition of his cause, freed from the constraints of technicalities. The Court applied this principle where counsel had relied in good faith on prior jurisprudence and the petition had already been filed before the extension was resolved.

• "NOW THEREFORE, the Court Resolves, for the guidance of the Bench and the Bar, to declare that Section 1, Rule 22 speaks only of 'the last day of the period' so that when a party seeks an extension and the same is granted, the due date ceases to be the last day and hence, the provision no longer applies. Any extension of time to file the required pleading should therefore be counted from the expiration of the period regardless of the fact that said due date is a Saturday, Sunday or a legal holiday." — This is the text of A.M. No. 00-2-14-SC as quoted in the decision, establishing the controlling rule on computation of extensions and clarifying that the next-working-day rule in Section 1, Rule 22 does not apply once an extension is sought and granted.

• "The underpinning consideration in Moskowsky, Vda. de Capulong and in the case at bar, is the liberal interpretation of the Rules to achieve substantial justice. Petitioner would be outright denied her right to appeal if the original period of December 26, 1998 would be the basis of the 15-day extension period. While the right to appeal is a statutory, not a natural right, nonetheless 'it is an essential part of our judicial system and courts should proceed with caution so as not to deprive a party of the right to appeal, but rather, ensure that every party-litigant has the amplest opportunity for the proper and just disposition of his cause, freed from the constraints of technicalities.'" — This passage from Labad vs. University of Southeastern Philippines, as quoted by the Court, articulates the doctrinal basis for the liberal interpretation applied in the case, justifying relaxation of procedural rules to serve substantial justice.

• Labad vs. University of Southeastern Philippines, 362 SCRA 510 (2001) — Cited by petitioner and relied upon by the Court for the principle of liberal interpretation of the Rules of Court to attain substantial justice. The Court distinguished it on the basis that A.M. No. 00-2-14-SC did not yet exist when Moskowsky (cited in Labad) was decided, but ultimately applied its underlying rationale to justify granting the petition.

• Moskowsky vs. Court of Appeals, 230 SCRA 657 (1994) — Cited in Labad as authority for the proposition that extensions may be reckoned from the next working day when the last day falls on a non-working day. The Court noted that A.M. No. 00-2-14-SC was not yet in existence when this ruling was promulgated, but recognized that petitioner's counsel had relied on it in good faith.

• Capulong vs. Workmen's Insurance Co., Inc., 178 SCRA 314 (1989) — Cited in Moskowsky and distinguished by the Court. The Court noted that the ruling in Capulong was anchored on an RTC order granting an extension without indicating when it would commence, unlike in the present case where the CA specifically stated the extension was reckoned from December 7, 2002.

• Section 1, Rule 22, 1997 Rules of Civil Procedure — Provides that in computing any period of time, the day of the act or event from which the period begins is excluded and the date of performance is included; if the last day falls on a Saturday, Sunday, or legal holiday, the time shall not run until the next working day. The provision was cited as the general rule on computation of time, but the Court clarified through A.M. No. 00-2-14-SC that it applies only to the last day of the period and not to extensions.

• A.M. No. 00-2-14-SC (February 29, 2000) — A Supreme Court resolution clarifying Section 1, Rule 22, declaring that when a party seeks and is granted an extension, the due date ceases to be the last day and the next-working-day provision no longer applies; any extension must be counted from the expiration of the original period regardless of whether the due date is a Saturday, Sunday, or legal holiday. The CA relied on this resolution in denying the petitioner's motions, and the Court acknowledged its correct application but relaxed its strict operation on grounds of substantial justice.

• Rule III, Section 4, NAC Administrative Order No. 2, Series of 1999 — Governs the period for filing a petition for review of the NAC's resolution with the Court of Appeals. Under this rule, the petitioner had fifteen days from receipt of the NAC resolution to file his petition for review, which period expired on December 7, 2002.

Justices Puno, Austria-Martinez, Tinga, and Chico-Nazario concurred. No separate concurring opinions were noted.