Case Summary (G.R. No. 177741)
Background of the Case
The case involves a dispute arising from Civil Case No. 51369, where the Regional Trial Court of Pasig ruled in favor of Asta Moskowsky against Antonio Doria. The private respondents, represented by their new counsel, appealed the decision and subsequently faced issues regarding the timeliness of their brief submissions to the Court of Appeals.
Motion for Extension of Time to File Brief
The Respondent Court of Appeals granted private respondents a non-extendible period of 90 days to file their brief, expiring on November 1, 1991. However, the private respondents filed for additional time on November 4, 1991, asserting that they required an extension due to the regular holiday on November 1 and subsequent holidays, which necessitated the delay in filing.
Petitioner’s Arguments
Moskowsky contended that the private respondents failed to adhere to procedural timelines as outlined in Section 15 of the Rules of Court. Specifically, she argued that their motions for extension were submitted after the reglementary period had expired and thus indicated a grave abuse of discretion by the appellate court in admitting the late filings.
Private Respondents’ Justifications
The private respondents countered Moskowsky's claims by explaining that the delays resulted from the time needed to assimilate new counsel and that their motions clearly specified the dates. They argued that the motions were legitimately time-sensitive due to the holidays, and thus the Court of Appeals exercised its discretion in the interest of justice by accepting their late submissions.
Application of Procedural Law
The Court analyzed the meaning of “good and sufficient cause” as defined in the applicable rules for filing extensions. The law states that if the due date falls on a holiday, the filing can be completed on the subsequent business day. The absence of actual business days due to holidays justified the timing of the private respondents' motions to the Court.
Precedential Cases and Judicial Discretion
In referencing prior similar cases, the Court acknowledged the principle that procedural rules should not be construed in a manner that would deny the opportunity for substantive justice. The
...continue readingCase Syllabus (G.R. No. 177741)
Case Overview
- Petitioner: Asta Moskowsky
- Respondents: Hon. Court of Appeals, Antonio Doria, Edgardo Alcaraz, Evangeline Doria
- G.R. No. 104222
- Date of Decision: March 03, 1994
- Jurisdiction: Second Division, Supreme Court of the Philippines
Background of the Case
- The case originated from Civil Case No. 51369 in the Regional Trial Court of Pasig Branch 161, Metro Manila, titled "Asta Moskowsky vs. Antonio Doria."
- A decision was rendered in favor of the petitioner on November 16, 1989.
- The private respondents filed an appeal, leading to the elevation of the records to the Court of Appeals, which docketed the appeal as CA-G.R. CV No. 30210.
Procedural History
- The Court of Appeals granted an extension on August 15, 1991, allowing private respondents 90 days to file their brief, ending on November 1, 1991.
- On November 4, 1991, private respondents filed an "Urgent Motion for a Final Extension of 20 Days to File Brief."
- Petitioner filed a Motion to Dismiss Appeal on November 4, 1991, citing the absence of the appellants' brief.
- Private respondents submitted additional motions for time extensions on November 25, 1991, and December 3, 1991, seeking to admit their bel