Title
Allam vs. Acosta
Case
G.R. No. L-20242
Decision Date
Jan 31, 1964
Appeal reinstated after multiple extensions for filing briefs; Supreme Court found no grave abuse of discretion despite excessive extensions, deeming issue moot.
A

Case Summary (G.R. No. L-20242)

Procedural History

Following a decision in Civil Case No. 1070, the defendants, including Valentina Acosta, filed an appeal that became CAG.R. No. 29551-R. The Clerk of the Court of Appeals informed the appellants on June 22, 1961, that they needed to remit a docketing fee of P198.75. The appellants failed to pay this fee within the designated timeline, prompting the appellees, represented by Francisco Allam and others, to move for the dismissal of the appeal, which the Court of Appeals granted on September 4, 1961.

Motion for Reconsideration and Extensions

Subsequently, on September 23, 1961, Atty. Vicente T. Velasco, Jr. entered an appearance for the appellants and filed a motion for reconsideration of the dismissal. The motion claimed that the delay in remitting the required fee was due to excusable negligence. The appellate court granted this motion on October 7, 1961, allowing the appeal to proceed. Several notices were then issued to file briefs, with multiple extensions granted at the request of various attorneys representing the appellants.

Delay in Filing Briefs

Atty. Velasco withdrew from representing the appellants in January 1962 due to conflicting interests, after which the appellants sought further extensions to file their brief. Between February and March 1962, the appellants changed counsel multiple times, which led to further requests for extensions. Ultimately, the Court of Appeals granted a final extension on March 28, 1962, allowing until May 10, 1962, for the filing of the brief.

Allegations of Grave Abuse of Discretion

Respondents filed a petition for certiorari arguing that the Court of Appeals exhibited grave abuse of discretion by allowing the appellants four extensions for filing the brief. The court's power to grant extensions is governed by Section 16, Rule 48, of the Rules of Court, which permits extensions for good and sufficient cause. While the motions for extensions were filed timely, the uniform reason of changing counsel was scrutinized as insufficient justification for the numerous extensions granted.

Court's Rationale and Decision

The decision expressed concern over the excessive delay caused by the frequent changes in counsel, commenting that the cumulatively exte

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