Montajes v. People

G.R. No. 183449 (March 12, 2012)

SC reinstated Alfredo Jaca Montajes' late petition for review, prioritizing justice over technicalities.

Facts:

Petitioner Alfredo Jaca Montajes was charged with Direct Assault under Article 148 of the Revised Penal Code for allegedly attacking Jose B. Rellon, an elected Punong Barangay, while Rellon was performing his official duties. The incident occurred on December 8, 2002, during a benefit dance in Barangay Abilan, Buenavista, Agusan del Norte. Rellon testified that Montajes approached him, verbally insulted him, and attempted to hack him with a bolo, although Rellon managed to evade the attack. Witnesses corroborated Rellon's account, stating they saw Montajes wielding the bolo and shouting that he was looking for those who had stoned his house.

Montajes, on the other hand, claimed he was merely looking for the individuals responsible for the stoning of his house and denied any intent to harm Rellon. He argued that his actions were a response to the provocation caused by the stoning incident. During barangay mediation, Montajes reportedly asked for forgiveness, but Rellon insisted on pursuing legal action.

The Municipal Trial Court (MTC) found Montajes guilty of Direct Assault and sentenced him to a prison term and a fine. Montajes appealed the MTC's decision to the Regional Trial Court (RTC), which affirmed the MTC's ruling. Following the RTC's denial of his motion for reconsideration, Montajes filed a petition for review with the Court of Appeals (CA), which was dismissed for being filed out of time.

Legal Issues:

  1. Whether the Court of Appeals erred in dismissing Montajes' petition for review on the grounds that it was filed out of time.
  2. Whether the computation of the period for filing the petition for review was correctly applied by the CA.

Arguments:

  • Petitioner (Montajes):

    • Montajes argued that he filed a motion for extension of time to file his petition for review, which was within the prescribed period. He contended that since the last day to file fell on a Saturday, the deadline should be moved to the next working day, which was a Monday. Therefore, he believed he was justified in requesting an extension from May 21, 2007, and that his petition filed on June 5, 2007, was timely.
    • He also requested the CA to consider the merits of his case, asserting that his conviction was not supported by sufficient evidence.

  • Respondent (People of the Philippines):

    • The prosecution maintained that Montajes' petition was indeed filed out of time, as the CA correctly calculated the deadline based on the original due date, which was May 19, 2007. They argued that the extension should be tacked onto the original period, making the petition filed on June 5, 2007, late.

Court's Decision and Legal Reasoning:

The Supreme Court granted Montajes' petition, setting aside the CA's resolutions that dismissed his petition for review. The Court clarified the application of Section 1, Rule 22 of the Rules of Court regarding the computation of time. It emphasized that when the last day for filing falls on a Saturday, Sunday, or legal holiday, the time does not run until the next working day. However, the Court also noted that if a motion for extension is granted, the new deadline should be counted from the expiration of the original period, not from the next working day.

In this case, while the CA was correct in its computation that Montajes' petition was late, the Court found that the circumstances warranted a liberal application of the rules in the interest of justice. The Court highlighted that Montajes had filed his petition for review before the CA dismissed it and that there was no evidence of prejudice to the respondent. The Court underscored the importance of allowing litigants to have their cases decided on the merits rather than on technicalities.

Significant Legal Principles Established:

  1. The computation of time for filing legal documents must consider weekends and holidays, and extensions should be calculated from the original due date.
  2. Courts may exercise discretion to relax procedural rules in the interest of justice, especially when the delay is minimal and does not prejudice the opposing party.
  3. The principle that litigations should be resolved on their merits rather than on technicalities is reinforced, emphasizing the need for fair and just determinations in legal proceedings.