G.R. No. 257401 - Linconn Uy Ong vs. Senate of the Philippines

Editha B. Albor was the agricultural lessee of a 1.60-hectare riceland and a 1.5110-hectare sugarland portion of Lot 2429 located at Barangay Dinginan, Roxas City.
The subject lot was registered under Transfer Certificate of Title (TCT) No. RT-108 (522) in the name of Rosario Andrada, married to Ramon Gardose.
As lessee, Editha consistently paid rent to the heirs of Rosario, who were the agricultural lessors.

On 22 September 2000, the Municipal Agrarian Reform Officer (MARO) invited Editha to the MARO office, where respondents informed her of the lot’s sale to them, although no deed of sale was initially produced.
Subsequently, on 7 November 2000, Editha secured from the RTC Clerk a document titled “Extra-Judicial Settlement with Deed of Sale,” allegedly executed by the heirs of Rosario, indicating that on 6 June 1997 the heirs adjudicated and then sold Lot 2429 to the respondents for P600,000.00.

Claiming her right to redeem the land under Section 12 of Republic Act No. 3844 (as amended by RA No. 6389), Editha filed a complaint for the redemption of Lot 2429 and damages before the Provincial Agrarian Reform Adjudicator (PARAD).
She argued that because the extrajudicial settlement had not been registered with the Register of Deeds, her 180-day redemption period had not commenced, entitling her to repurchase the lot at a lower price of P60,000.00.

Respondents contended that Editha was aware that the actual selling price was P600,000.00.
They referenced discussions from 21 April 1997, where lawyer Atty. Alejandro Del Castillo and Eva Gardose-Asis explained to Editha and her son her preemptive right, offering the lot at P600,000.00.
Respondents further submitted that Editha had received a written notice dated 16 March 1998, informing her of the sale and offering her an opportunity to repurchase.
They later demanded the payment of back rentals which Editha contested by instituting the redemption complaint.

In its 30 June 2003 decision, the PARAD found that Editha was not properly notified of the sale because the notice lacked sufficient details, thus ruling that her right of redemption did not prescribe.
However, the PARAD dismissed her complaint on the ground that only P216,000.00 was consigned as the redemption price, far short of the P600,000.00 purchase price stated in the extrajudicial settlement and deed of sale.
The decree ordered various measures, including payment of back rentals, maintenance of peaceful possession, and enforcement of an agricultural lease contract backed by the intervention of the Department of Agrarian Reform.

Editha’s appeal was filed before the Department of Agrarian Reform Adjudication Board (DARAB) on 8 October 2008, which affirmed in toto the PARAD ruling.
On 25 November 2008, she filed a motion for extension of time before the Court of Appeals (CA) to file a Rule 43 petition for review, asking for an additional fifteen (15) days.
On 3 December 2008, a motion to withdraw as counsel was filed by her then counsel, Atty. Fredicindo A. Talabucon, which Editha signed off, indicating a change in representation.
On 9 December 2008, her new counsel, Atty. Ferdinand Y. Samillano, appeared and moved for an additional extension of thirty (30) days to file the petition for review.
Ultimately, Editha’s petition for review was filed on 5 January 2009, but it was challenged on the ground of procedural noncompliance regarding the filing period.

The CA, in its resolution dated 24 September 2009, dismissed Editha’s petition for review on the basis that it was filed out of time.
The CA noted that while a first extension of fifteen (15) days was permissible, its rules did not allow a second extension beyond the prescribed period.
A motion for reconsideration was subsequently filed by Editha but was denied in the CA’s 15 February 2011 resolution.
Editha then elevated her case to the Supreme Court via a petition for certiorari under Rule 65, contesting the CA’s dismissal.

Whether the Court of Appeals erred in dismissing Editha’s petition for review on the grounds that it was filed out of time.

Whether Editha made use of the proper procedural remedy by filing a petition for review under Rule 45 rather than a petition for certiorari under Rule 65.
Whether the extension for filing the petition for review, particularly the second extension requested by Editha’s new counsel, was justified given the circumstances.
Whether the procedural mishandling by Editha regarding counsel withdrawal and subsequent delay affected her substantive right to redeem the land.