The Supreme Court ruled that a petition for relief from judgment, seeking to overturn a lower court’s decision due to the negligence of a lawyer, must be filed within a strict timeframe: 60 days from notice of the judgment and six months from the judgment’s entry. This ruling underscores the importance of adhering to procedural deadlines in legal proceedings, emphasizing that failure to do so, even due to a lawyer’s alleged negligence, can result in the loss of legal recourse.

Can Old Age Excuse Legal Delay? When Timelines Trump Sympathy in Court

This case revolves around Spouses Jesus and Carolina Morales filing a judicial foreclosure complaint against Juliet Vitug Madarang, Romeo Bartolome, and Spouses Rodolfo and Ruby Anne Bartolome, seeking to recover a loan secured by a mortgage on a property in Quezon City. After the trial court ruled against the defendants, their attempt to appeal was denied due to the late filing of the notice of appeal. The defendants then filed a petition for relief from judgment, citing the advanced age and alleged negligence of their lawyer as the reason for the delay. The central legal question is whether the failure to file a timely appeal, attributed to the lawyer’s age-related negligence, constitutes excusable negligence that warrants relief from judgment.

The Supreme Court addressed two critical issues: first, whether the failure of the petitioners’ former counsel to file the notice of appeal within the mandated period constitutes excusable negligence; and second, whether the Court of Appeals erred in dismissing the petitioners’ petition for certiorari due to their failure to file a motion for reconsideration of the order that denied their petition for relief from judgment. The court emphasized the importance of adhering to the timelines set forth in Rule 38, Section 3 of the 1997 Rules of Civil Procedure, which dictates that a petition for relief from judgment must be filed within 60 days after the petitioner learns of the judgment and within six months from the entry of judgment.

Strict compliance with these periods is jurisdictional, and failure to meet them results in the outright dismissal of the petition. The Court noted that the petition for relief from judgment was filed out of time, as it was filed beyond six months from the finality of the trial court’s decision. Even if the petition had been filed within the prescribed period, the Court found that the petitioners failed to demonstrate that their former counsel’s failure to file a timely notice of appeal was due to excusable negligence. The Court clarified that to warrant relief, the negligence must be so gross that ordinary diligence and prudence could not have guarded against it.

In the case of Gesulgon v. National Labor Relations Commission, the Supreme Court underscored the stringent requirements for filing a petition for relief from judgment, emphasizing the need for strict adherence to the reglementary periods. Similarly, in Spouses Reyes v. Court of Appeals and Voluntad, the Court reiterated that the 60-day period from knowledge of the decision and the 6-month period from entry of judgment are both inextendible and uninterruptible. The Supreme Court stated,

“A party filing a petition for relief from judgment must strictly comply with two (2) reglementary periods: (a) the petition must be filed within sixty (60) days from knowledge of the judgment, order or other proceeding to be set aside; and (b) within a fixed period of six (6) months from entry of such judgment, order or other proceeding.”

The court pointed out that the petitioners could not argue that the period to appeal should be counted from the date they personally received a copy of the trial court’s decision, as notice of judgment to the counsel of record constitutes notice to the client.

Furthermore, the Court rejected the argument that the former counsel’s advanced age constituted excusable negligence, deeming it a stereotype that demeans senior citizens. The Supreme Court made clear that there was no showing that the negligence could not have been prevented through ordinary diligence and prudence, and as such, the petitioners were bound by their counsel’s negligence. Consequently, the Court found that the trial court had correctly denied the notice of appeal for having been filed out of time, and upheld the Court of Appeals’ denial of the petition for certiorari for failure to file a motion for reconsideration of the order denying the petition for relief from judgment.

Regarding the failure to file a motion for reconsideration, the Court cited Metro Transit Organization, Inc. v. PIGLAS NFWU-KMU, which affirmed that a motion for reconsideration is a plain, speedy, and adequate remedy that must be availed of before filing a petition for certiorari. The court explained,

“[t]he filing of the motion for reconsideration before availing of the remedy of certiorari is not sine qua non when the issues raised is one purely of law.”

However, the Court found that the questions raised by the petitioners were not purely questions of law, as they involved factual issues such as the authenticity of signatures and the alleged excusable negligence of their counsel.

FAQs

What is a petition for relief from judgment?	It’s a legal remedy to set aside a judgment due to fraud, accident, mistake, or excusable negligence, offering a ‘last chance’ to an aggrieved party.
What are the time limits for filing a petition for relief?	It must be filed within 60 days after learning of the judgment and no more than six months after the judgment was entered.
What constitutes ‘excusable negligence’ in this context?	Negligence so gross that ordinary diligence and prudence couldn’t have prevented it, not merely a lawyer’s age.
Is notice to a lawyer considered notice to the client?	Yes, notice of judgment to the counsel of record is legally considered notice to the client.
Why was the appeal in this case denied?	Because the notice of appeal was filed after the 15-day period from the counsel’s receipt of the order denying the motion for reconsideration.
What is a motion for reconsideration, and why is it important?	It’s a request to the court to re-examine its decision, and it’s a necessary step before filing a petition for certiorari.
What is a petition for certiorari?	It’s a legal remedy to correct errors of jurisdiction or grave abuse of discretion by a lower court.
Can a lawyer’s old age be considered ‘excusable negligence’?	No, the court rejected the argument that a lawyer’s old age is an acceptable excuse for negligence.
What happens if a petition for relief is filed late?	The petition will be dismissed outright, as the timelines are strict and jurisdictional.

The Supreme Court’s decision in this case reinforces the importance of adhering to procedural rules and timelines in legal proceedings. While the case presents a sympathetic narrative of potential negligence due to a lawyer’s advanced age, the court emphasizes that the strict application of the rules is necessary to ensure the finality of judgments and the efficient administration of justice. Litigants must be vigilant in monitoring their cases and ensuring that their lawyers act diligently within the prescribed timeframes.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Madarang v. Morales, G.R. No. 199283, June 09, 2014