Case Summary (G.R. No. 210861)
Relevant Facts
CBSUA, established under Batas Pambansa Bilang (BP) 198 and later amended by Republic Act No. 9717, was designated as a state university overseeing agricultural education. Several real properties were transferred to CBSUA under these laws, including specific parcels of land detailed in Original Certificate of Title (OCT) No. 1029. In 1998, the Province of Camarines Sur sought to reconstitute this title, resulting in OCT RO-917 and subdividing certain lots. Tensions escalated when armed personnel from the Province forcibly entered a portion of the land occupied by CBSUA, disrupting its educational purposes, particularly in agricultural and veterinary studies.
Legal Proceedings Initiated by CBSUA
In response to the Province's actions, CBSUA filed a complaint on April 12, 2011, seeking recovery of ownership, possession, and damages. It requested a temporary restraining order (TRO) against the Province and GKFI, aiming to prevent construction activities on the subject land. The case was assigned to the Regional Trial Court (RTC) of Pili, Camarines Sur, which subsequently denied CBSUA’s application for a TRO in a May 12, 2011, order. The RTC opined that CBSUA failed to demonstrate superior rights to the land against those of the Province, citing CBSUA's lack of a registered certificate of title in its favor.
RTC’s Orders and Subsequent Appeal
CBSUA's motion for reconsideration was denied on October 10, 2011. The Office of the Solicitor General, representing CBSUA, encountered delays in securing necessary documentation and thus sought an extension to file a petition for certiorari, which they submitted on December 26, 2011, albeit ten days past the deadline. The Court of Appeals (CA) denied the motion for extension in its February 2, 2012, resolution and dismissed the petition outright due to late filing.
Court of Appeals’ Ruling
The CA ruled that the amendment to Section 4, Rule 65 of the Rules of Court as introduced by A.M. No. 07-7-12-SC entirely eliminated the previously allowable extension for late filing of petitions for certiorari. Consequently, CBSUA’s petition was declared out of time, leading to its dismissal based on procedural grounds.
Issue Presented Before the Supreme Court
This case presents the critical issue of whether the CA erred in its interpretation that extensions for filing petitions for certiorari have been completely disallowed under the amended rules.
Supreme Court’s Ruling
The Supreme Court granted CBSUA's petition. While acknowledging the rule that typically requires strict adherence to the 60-day timeline for filing petitions, it noted that exceptions do exist under compelling circumstances or where strict application of the rules would result in injustice. Th
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Case Reference
- G.R. No. 210861
- Date of Decision: July 29, 2015
- Court: Supreme Court of the Philippines, First Division
- Petitioner: Central Bicol State University of Agriculture, represented by its President, Atty. Mario T. Bernales
- Respondents: Province of Camarines Sur, represented by Governor Luis Raymundo F. Villafuerte, Jr. and Gawad Kalinga Foundation, Inc., represented by its Executive Director, Jose Luis Oquiaena, and Chapter Head, Harry Azana
Background of the Case
- The case revolves around a petition for review on certiorari against the Resolutions dated February 2, 2012, and July 24, 2012, issued by the Court of Appeals (CA).
- The CA denied the motion for extension of time to file a petition for certiorari and subsequently dismissed the certiorari petition outright for being filed out of time.
Facts of the Case
- Petitioner: Central Bicol State University of Agriculture (CBSUA) is a government educational institution primarily focused on advanced instruction and research in agriculture.
- CBSUA was established under Batas Pambansa Bilang (BP) 198 and later converted to a state university by Republic Act No. 9717.
- Property Grant: Under Section 17 of BP 198, certain real properties were granted to CBSUA, including parcels of land registered under Original Certificate of Title (OCT) No. 1029 in the name of the Province of Camarines Sur.
- In 1998, the Province sought to reconstitute OCT No. 1029, which led to its reconstitution as OCT RO-917 and subsequent subdivision into lots.
- Dispute: In February 2011, armed personnel from the Province forcibly entered a po