Reinier Pacific International Shipping, Inc. vs. Guevarra

When an extended period for filing a pleading falls on a Saturday, Sunday, or legal holiday, the pleading may be filed on the next working day, because the extended due date remains "the last day of the period" under Section 1, Rule 22 of the Rules of Court.

Reinier Pacific International Shipping, Inc. acted as the local agent for Neptune Ship Management Services, PTE., Ltd., hiring Captain Francisco B. Guevarra as master of MY NOL SHEDAR. The dispute arose from Guevarra's dismissal from his post, which he contested as illegal. The resolution of the illegal dismissal case before the labor tribunals eventually spawned a petition for certiorari before the Court of Appeals, the procedural timeliness of which is the core issue in this case.

On May 3, 2000, Reinier Pacific International Shipping, Inc. hired Captain Francisco B. Guevarra to serve as master of MY NOL SHEDAR. During his employment, Reinier Shipping relieved Guevarra of his command upon the insistence of the vessel's charterers and owners, citing an incident where a hatch cover was damaged while discharging coal in Alabama, U.S.A. Guevarra claimed the damage was caused by cargo-handling stevedores and filed a case for illegal dismissal and damages, asserting that he was denied due process because the company did not investigate his guilt and merely yielded to the charterers' demands.

The Labor Arbiter ruled in Guevarra's favor, finding the dismissal illegal and ordering Reinier Shipping and its principal to pay his remaining salaries and attorney's fees. The National Labor Relations Commission affirmed this decision on February 22, 2002. Reinier Shipping then sought to file a petition for certiorari before the Court of Appeals. The original due date fell on July 26, 2002, a Friday. The company secured a 15-day extension, making the new due date August 10, 2002, a Saturday.

Because August 10 fell on a Saturday when courts were closed, Reinier Shipping filed its petition on the following Monday, August 12, 2002. The Court of Appeals dismissed the petition on November 11, 2002, for being filed out of time, reasoning that under A.M. 00-2-14-SC, the fact that the extended due date fell on a Saturday should be disregarded, compelling the company to file on or before Friday, August 9. This procedural dismissal prompted the present petition.

• Timeliness of Filing: Petitioner argued that the Court of Appeals erred in dismissing its petition for having been filed out of time, asserting that since the extended due date fell on a Saturday, the filing on the next working day, Monday, was proper under Section 1, Rule 22 of the Rules of Court.

• Timeliness of Filing: Whether the Court of Appeals erred in dismissing the petition for certiorari for being filed out of time when the extended period for filing fell on a Saturday and the pleading was filed on the next working day.

• Timeliness of Filing: Yes. The CA erred in dismissing the petition. When an extended period for filing a pleading falls on a Saturday, Sunday, or legal holiday, Section 1, Rule 22 of the Rules of Court applies, allowing the pleading to be filed on the next working day.

• Timeliness of Filing: The interplay between Section 1, Rule 22 of the Rules of Court and A.M. 00-2-14-SC was clarified. Section 1, Rule 22 provides that if the last day of the period falls on a Saturday, Sunday, or legal holiday, the time shall not run until the next working day. A.M. 00-2-14-SC clarifies that when an extension is sought, the extended period is counted from the original expiration date, regardless of whether that original due date falls on a weekend or holiday. However, the extended due date itself becomes the new "last day of the period." Thus, if this new due date falls on a Saturday, Sunday, or legal holiday, Section 1, Rule 22 again applies, moving the deadline to the next working day. The CA's interpretation would have unjustly deprived the petitioner of the full benefit of the 15-day extension by compelling it to file a day short. Since August 10 was a Saturday and courts were closed, filing on Monday, August 12, was timely.

• Computation of Extended Periods — When the last day of an extended period for filing a pleading falls on a Saturday, Sunday, or legal holiday, the pleading may be filed on the next working day. A.M. 00-2-14-SC merely clarifies that the extension is counted from the original expiration date, but it does not remove the application of Section 1, Rule 22 to the new, extended due date. The extended due date is still considered "the last day of the period."

• "But this is obviously wrong since it would mean compelling Reinier Shipping to file its petition one day short of the 15-day extension granted it. That would unjustly deprive it of the full benefit of that extension. Since its new due date fell on a Saturday when courts are close, however, the clear language of Section 1, Rule 21, applies. This gives Reinier Shipping up to Monday (August 12), the next working day, within which to file its petition." — This passage articulates the ratio decidendi, emphasizing that parties must enjoy the full benefit of an extension and that the next-working-day rule applies to extended due dates falling on weekends or holidays.

• Section 1, Rule 22, Rules of Court — Governs the computation of time, providing that if the last day of the period falls on a Saturday, Sunday, or legal holiday, the time shall not run until the next working day. The Court applied this to the extended due date, holding that the extended due date is still the "last day of the period."
• A.M. 00-2-14-SC — Clarifies the application of Section 1, Rule 22 when the original period is extended, stating that the extension should be counted from the expiration of the original period regardless of whether it falls on a weekend or holiday. The Court clarified that this administrative matter does not preclude the application of the next-working-day rule to the newly computed extended due date.

Presbitero J. Velasco, Jr. (Chairperson), Diosdado M. Peralta, Jose Catral Mendoza, and Marvic Mario Victor F. Leonen.