Case Summary (G.R. No. 128805)
Background of the Case
The Regional Trial Court of Manila, Branch 48, issued a decision on August 31, 1995, in Special Proc. No. 92-62305 that favored the petitioner, Ma. Imelda Argel, against the respondent, Rosendo G. Guevarra. The ruling involved the distribution of Guevarra's share in his mother's estate to their son, Victorio Guevara. The trial court ordered specific amounts to be delivered to Victorio, alongside monthly educational support, and awarded damages to Argel, which included interest on the presumptive legitime.
Procedural History
After receiving the decision on September 11, 1995, the petitioner filed a motion for extension of time to file a reconsideration only 15 days later, on September 26, 1995. While awaiting resolution, she subsequently filed a motion for reconsideration on September 29, 1995. This led to an objection from the respondent based on the Habaluyas doctrine which prohibits extensions for filing motions for reconsideration. The trial court later issued an order on December 12, 1995, favoring Argel's motion but was subsequently contested by the respondent through a petition for certiorari to the Court of Appeals.
Court of Appeals' Decision
The Court of Appeals granted Guevarra's petition for certiorari on December 20, 1996, thereby reversing the trial court's order. It held that the trial court exercised grave abuse of discretion in admitting Argel's motion for reconsideration, citing the established doctrine which does not allow extensions for such motions. The appellate court provided a temporary restraining order against the trial court's earlier orders.
Issues Presented to the Supreme Court
In seeking review, the petitioner presented four key issues, namely: (1) Whether the Court of Appeals incorrectly determined that the trial court acted with grave abuse of discretion; (2) Whether there was a violation of the rule on forum shopping; (3) Whether the denial of the motion for reconsideration by the appellate court was erroneous; and (4) If the appellate court's decision was unjust toward the petitioners' rights concerning family support.
Analysis of Court Findings
The Supreme Court analyzed two primary issues: the appellate court's decision regarding the trial court's discretion and the allegation of forum shopping. The Court reinforced the doctrine established in Habaluyas vs. Japzon, stating that the 15-day period for filing appeals is non-extendible. The Court held that the trial court's rationale for granting the extension based on the petitioner’s res
...continue readingCase Syllabus (G.R. No. 128805)
Case Overview
- This case involves a petition for review filed under Rule 45 of the Rules of Court, challenging the Decision of the Court of Appeals dated December 20, 1996, and the subsequent Resolution on March 31, 1997, which denied the petitioners' motion for reconsideration.
- The Court of Appeals granted the petition for certiorari of private respondent Rosendo G. Guevara and set aside the trial court's Order dated December 12, 1995.
Procedural History
- On August 31, 1995, the Regional Trial Court of Manila, Branch 48, issued a decision in Special Proc. No. 92-62305.
- The trial court's decision ordered Rosendo G. Guevara to deliver a specific amount to his son, order monthly support, and pay damages to Ma. Imelda Argel.
- Ma. Imelda Argel's counsel received the trial court's decision on September 11, 1995, while Rosendo G. Guevara received his copy on September 21, 1995.
- On September 26, 1995, Argel's counsel filed a motion for extension of time to file a motion for reconsideration, citing a heavy workload.
- Despite not waiting for the resolution of the extension, a motion for reconsideration was filed on September 29, 1995, after the 15-day period had lapsed.
Key Issues
- The Court of Appeals found that the trial court