G.R. No. 161722 - G.Q. Garments, Inc. vs. Miranda

In Civil Case No. 51369 at the Regional Trial Court of Pasig Branch 161, a decision was rendered on November 16, 1989 in favor of petitioner Asta Moskowsky.
Private respondents (Antonio Doria, Edgardo Alcaraz, and Evangeline Doria) appealed that decision.
The records of the case were elevated to the Court of Appeals, which docketed the matter as CA.G.R. CV No. 30210.
An initial "Urgent Ex-Parte Motion For Extension of Time To File Brief" was filed by private respondents’ former counsel on August 2, 1991, requesting a 90-day extension starting from August 3, 1991, which would end on November 1, 1991.

On November 4, 1991, private respondents—through newly appointed counsel—filed an "Urgent Motion for a Final Extension of 20 Days to File Brief."
On the same day (November 4, 1991), petitioner filed a Motion to Dismiss the Appeal, arguing that no appellants’ brief had been filed within the reglementary period ending November 1, 1991.
On November 25, 1991, private respondents filed an "Urgent Motion for Five (5) Days to File Brief."
On December 3, 1991, private respondents filed a "Motion to Admit Appellants’ Brief."
A Motion for Reconsideration was filed by petitioner on January 6, 1992, arguing that the extension motions were untimely, and the CA’s admission of the brief was in violation of Section 15, Rule 46 of the Rules of Court.
The Court of Appeals denied petitioner’s Motion for Reconsideration in its resolution dated February 19, 1992.

The original ninety-day period ended on November 1, 1991, which was a regular holiday.
November 2, 1991 was declared a special holiday by President Aquino, and November 3, 1991 fell on a Sunday.
Consequently, the next working day became November 4, 1991.
Private respondents argued that because of these holidays, the filing of motions on November 4 and November 25, 1991 was timely as the extended periods should commence from the first business day following the holidays.

Petitioner contended that the "Urgent Motion for a Final Extension of 20 Days" filed on November 4, 1991 did not alter the reglementary expiration, which should have been November 1, 1991.
Petitioner further argued that the extension period should have run from November 1 to November 21, 1991, making the subsequent filing on November 25, 1991 four days late and the filing of the brief on December 3, 1991 out of time.
In contrast, private respondents asserted that the motions clearly stated the desired periods for filing, which were adjusted to account for intervening holidays and non-working days.

In their motion, private respondents explained that the need for an additional five-day extension was due to the requirement for the new counsel to review records thoroughly, compounded by a change of counsel.
A delay of one day in the actual filing of the brief (filed on December 3, 1991, rather than on December 2, 1991) was attributed to typographical errors necessitating retyping of some pages.

Whether the filing of the "Urgent Motion for a Final Extension of 20 Days" on November 4, 1991, properly adjusted the deadline for filing the appellants’ brief considering the holidays.
Whether the subsequent "Urgent Motion for Five (5) Days to File Brief" filed on November 25, 1991 was a timely and appropriate request given the circumstances of the holidays and weekends.

Whether the filing of the "Motion to Admit Appellants’ Brief" on December 3, 1991, though one day late, can be excused on the grounds of technical difficulties (typing errors) and the judicial principle of equity.

Whether the Court of Appeals abused its discretion in admitting the motions and the brief despite the alleged technical tardiness as argued by petitioner.

Whether private respondents’ motions complied with the requirement that a motion for extension of time must be filed before the expiration of the period sought to be extended.