The Supreme Court clarified that
procedural rules are designed for the orderly conduct of proceedings and
expeditious settlement of cases in the courts of law. Like all rules,
they are required to be followed and utter disregard of the same cannot be
expediently rationalized by harping on the policy of liberal construction which
was never intended as an unfettered license to disregard the letter of the law
or, for that matter, a convenient excuse to substitute substantial compliance
for regular adherence thereto. When
it comes to compliance with time rules, the Court cannot afford
inexcusable delay. (J. TIOSEJO INVESTMENT CORP vs. SPOUSES
BENJAMIN AND ELEANOR ANG, G.R. No. 174149, September 8, 2010, PEREZ, J.).
How to
compute time. — In computing any period of time prescribed or allowed by these
Rules, or by order of the court, or by any applicable statute, the day of
the act or event from which the designated period of time begins to run is to
be excluded and the date of performance included. If the last day of the
period, as thus computed, falls on a Saturday, a Sunday, or a legal holiday in
the place where the court sits, the time shall not run until the next working
day (Section 1 of Rule 22 of the Rules of Court). x x x In Alma Russel vs. Teofista Ebasan, the Supreme Court ruled that when
petitioner filed her petition for review with the appellate court on May 15,
2007, the same was well within the extended period for the filing thereof. This
is true because petitioner’s Fifteen (15) days from April 28, 2007 would be May
13, 2007. This was, however, a Sunday. On the other hand, May 14, 2007, the
following day, was a legal holiday—the holding of the national and local
elections. Therefore, the filing of petition the petition on May 15, 2007 was
done within the reglementary period. (ALMA B. RUSSEL vs. TEOFISTA EBASAN and AGAPITO AUSTRIA, G.R. No. 184542, April 23, 2010, NACHURA, J.:)
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