G.R. No. 203918 - Spouses Cayago, Jr. vs. Spouses Cantara

Spouses Amador C. Cayago, Jr. and Ermalinda B. Cayago (Sps. Cayago) filed a petition for review on certiorari before the Supreme Court, challenging decisions rendered by the Court of Appeals (CA).
The CA had dismissed Sps. Cayago’s petition for review on the ground that it was filed beyond the reglementary period.

The dispute originated from a complaint for forcible entry, preliminary mandatory injunction, and damages filed by spouses Evelito and Soledad Cantara (Sps. Cantara) on January 17, 2008, asserting their rightful ownership and actual possession of a 1,722-square meter agricultural (riceland) parcel located in Brgy. Surok, Borongan, Eastern Samar.
Sps. Cantara alleged that they acquired the subject land in 1993 from Asteria Rubico, who herself had acquired it in 1979 from Justina Alegre, daughter of the original owner, Simona Capito.
Evidence of their ownership included a deed of absolute sale and supporting documentary evidence such as the Tax Declaration and the sworn statements of their tenants, who had been cultivating the land for them.

In December 2007, Sps. Cayago, with hired hands and without the notice of Sps. Cantara or their tenants, forcefully entered the subject land, cleared it, and planted palay (rice), thereby depriving Sps. Cantara and their tenants of access.
Sps. Cantara responded by demanding that Sps. Cayago vacate and surrender their possession of the land, which culminated in the filing of the complaint before the Municipal Trial Court (MTC) of Borongan, Eastern Samar as Civil Case No. (2008-02)764.

In its decision dated February 27, 2009, the MTC dismissed the complaint for lack of merit, finding that Sps. Cayago had sufficiently proven ownership and prior physical possession of the subject land by presenting OCT No. P-7694, various Tax Declarations, and the Commissioner’s Report.
The court recognized the government’s rigorous process for securing the OCT, thereby acknowledging the established possession by Sps. Cayago.

On August 14, 2009, the Regional Trial Court (RTC) reversed the MTC’s decision, ruling in favor of Sps. Cantara and ordering Sps. Cayago, along with their agents, to surrender possession of the subject land and pay reasonable rent from December 2007 until actual surrender.
The RTC emphasized that Sps. Cantara had discharged their burden of proving prior physical possession using various pieces of evidence, including a notarized Deed of Sale and the testimonies of tenants.

Sps. Cayago’s motion for reconsideration was filed on September 14, 2009, and later denied by the RTC on July 6, 2010.
Under Section 1, Rule 42 of the Rules of Court, Sps. Cayago were required to file a petition for review within fifteen (15) days from notice of the RTC decision.
A motion for an extension of time was filed on July 29, 2010, seeking an additional 15 days to file the petition for review.
Due to the motion being received by the CA after the last day prescribed for filing (the rollo reached the ponente’s office on January 5, 2011), the petition for review was deemed belated.

In its decision dated April 14, 2011, the CA dismissed Sps. Cayago’s petition for review, holding that the mere filing of a motion for extension does not guarantee an extension as such motions are discretionary and subject to strict compliance with the reglementary periods.
The CA also identified additional infirmities in the petition such as deficiencies in the notarization details and lack of explanation for non-personal filing.

Dissatisfied with the CA’s dismissal and subsequent denial of the motion for reconsideration dated September 27, 2012, Sps. Cayago elevated the case to the Supreme Court.
The sole issue on certiorari was the alleged reversible error committed by the CA in dismissing the petition for review on technical, procedural grounds not attributable to the petitioners.

Whether the CA erred in dismissing Sps. Cayago’s petition for review solely on the ground that it was filed out of time.

Whether the proper motion for extension of time filed by Sps. Cayago, despite its late action in the ponente’s office, should excuse the procedural default.
Whether the strict application of reglementary periods in the filing of appeals may be relaxed in light of substantial justice and due process considerations.