GR No. 123456, *Santos v. Reyes* (2020)

FACTS: Juan Santos filed a complaint for ejectment against Maria Reyes before the Metropolitan Trial Court (MeTC), alleging that Reyes was unlawfully withholding possession of a residential property. The MeTC ruled in favor of Santos and ordered Reyes to vacate the premises. Reyes appealed to the Regional Trial Court (RTC), which reversed the MeTC decision. Santos then filed a Petition for Review with the Court of Appeals (CA). The CA dismissed the petition for being filed one day late. Santos moved for reconsideration, arguing that the last day for filing fell on a Saturday and that he filed on the next working day, Monday. The CA denied the motion, insisting that the reglementary period is absolute and non-extendible. Santos elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in dismissing the petition for being filed one day late, considering that the last day of the reglementary period fell on a Saturday.

RULING

Yes, the Court of Appeals erred. The Supreme Court granted the petition and reinstated Santos’s appeal.

The Court held that under Section 1, Rule 22 of the Rules of Court, if the last day of a period for doing any act required or allowed by law falls on a Saturday, a Sunday, or a legal holiday, the act may be done on the next working day. This rule applies to reglementary periods for appealing or filing pleadings. The CA’s strict application, which disregarded the rule on holidays, constituted a grave abuse of discretion. The Supreme Court emphasized that procedural rules are tools to facilitate justice, not to frustrate it. Since Santos filed his petition with the CA on the next working day following a Saturday, the filing was timely. The case was remanded to the CA for proper proceedings on the merits.