G.R. No. 210861 - Central Bicol State University of Agriculture vs. Province of Camarines Sur

CBSUA, a government educational institution, was established to provide advanced instruction and research in agriculture and allied sciences.
The institution evolved from the Camarines Sur Agricultural College, which was first converted into a state college under Batas Pambansa (BP) 198 and subsequently into a state university under Republic Act (RA) 9717.
Under Section 17 of BP 198, several real properties were granted to the institution, including parcels of land originally held by the Province of Camarines Sur.
RA 9717 confirmed the transfer of assets, liabilities, personnel, and records to CBSUA, with the understanding that any land not needed in the future would revert to the national government.

In 1998, the Province of Camarines Sur initiated proceedings to reconstitute the Original Certificate of Title (OCT) No. 1029, which covered one of the granted parcels of land.
Subsequent to reconstitution, OCT No. 1029 was changed to OCT RO-917, and one of its lots was subdivided into two: Lot 3-P-1 (561,945 square meters) and Lot 3-P-2 (63,829 square meters).
Lot 3-P-1 later became covered by Transfer Certificate of Title (TCT) No. 41093, which would later be at the center of the dispute.

Around February 2011, armed personnel deployed by the Province allegedly forcibly entered a portion of Lot 3-P-1, which was under the occupation of CBSUA.
These actions involved the destruction of fences and other structures erected by CBSUA, thereby hindering its use of the land as pasture for large cattle utilized in laboratory experiments by its students.
CBSUA later discovered that the Province had allocated the subject land for a housing project for rebel returnees, managed by the Gawad Kalinga Foundation, Inc. (GKFI).

On April 12, 2011, CBSUA filed a complaint for recovery of ownership, possession, and damages against the Province and GKFI.
The complaint also included a prayer for the issuance of a temporary restraining order (TRO) and/or writ of preliminary mandatory injunction to maintain the status quo, order the vacating of the subject land, or prevent construction or the advancement of the housing project.
The case was raffled to the Regional Trial Court (RTC) of Pili, Camarines Sur, Branch 32, where hearings were conducted commencing on April 27, 2011.

On May 12, 2011, the RTC denied the TRO and/or preliminary injunction application, finding that while CBSUA had valid legal basis under the relevant laws, its failure to register the title in its name meant it could not show a superior right over the property against the registered owner, the Province.
A motion for reconsideration filed by CBSUA was denied on October 10, 2011.
CBSUA was given until December 16, 2011, to file a petition for certiorari under Rule 65 of the Rules of Court. However, due to delays in securing necessary documents, CBSUA filed the petition on December 26, 2011, which was ten (10) days beyond the prescribed 60-day reglementary period.

Whether or not the Court of Appeals erred in ruling that the petition for certiorari, filed ten days after the expiration of the 60-day reglementary period, was untimely and should be dismissed outright.
The issue also contemplates whether the amendment introduced by A.M. No. 07-7-12-SC to Section 4, Rule 65 of the Rules of Court leaves no room for extensions or motions for extension in filing a petition for certiorari even under exceptional circumstances.