G.R. No. 211443 - East Asia Utilities Corp. vs. Arenas

Petitioner: Antonio C. San Luis, Administrator of the Light Rail Transit Authority (LRTA).
Respondents: Court of Appeals, Hon. Nelson Bayot (presiding judge, RTC Pasay City, Branch 118) and T.N. Lal & Co., Ltd.
Nature of the action: A petition for indirect contempt filed by T.N. Lal & Co., Ltd. arose from petitioner’s alleged failure to comply with a judicial order.

On 7 April 1999, Hon. Ernesto A. Reyes, presiding judge of Branch 111 of the Regional Trial Court, issued an order directing the LRTA to immediately restore the power supply of the petitioner’s sound system at all affected locations within 24 hours.
The noncompliance with this order led to the filing of a petition for indirect contempt by T.N. Lal & Co., Ltd., which was docketed as Civil Case No. 99-0480 and raffled to Branch 118 of the RTC.

Petitioner filed a motion to dismiss the contempt petition on two grounds: absence of a cause of action and the allegation that private respondent was guilty of forum-shopping.
On 15 July 1999, Judge Nelson Bayot ordered that the contempt petition be transferred from Branch 118 to Branch 111—where the original order was issued—on the basis that that branch was in a better position to evaluate compliance with the order.
Petitioner sought reconsideration of the transfer order by filing a motion on 18 August 1999; however, Judge Bayot, reaffirming his earlier decision, administratively confirmed the transfer on 22 October 1999.

On 7 January 2000, petitioner filed a petition for certiorari and mandamus under Rule 65 of the Rules of Court, challenging the transfer order on the ground of grave abuse of discretion and excess of jurisdiction.
Petitioner argued that the petition was filed late due to an honest mistake and human error by the handling counsel in computing the filing period.
The Court of Appeals, in its Resolution of 24 January 2000, dismissed the petition on the ground of tardiness.
A subsequent motion for reconsideration and a motion to admit the petition—coupled with a request to relax strict procedural rules—were both denied by the Court of Appeals on 13 March 2000.

Whether the petition for certiorari and mandamus was filed out of time.
Whether the failure to file within the prescribed period was due to an honest mistake and administrative error, thereby warranting a liberal construction of the procedural rules.

Whether Judge Bayot committed grave abuse of discretion or acted without or in excess of jurisdiction by transferring the petition for indirect contempt from Branch 118 to Branch 111.
Whether the proper forum for adjudication of the indirect contempt issue should remain with the court that originally issued the order.

Whether the petition should be reinstated to enable a merit determination rather than being dismissed on a mere technicality.
How the retroactive application of amendments to Section 4, Rule 65 affects the computation of the filing period in pending cases.