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JAIME BELTRAN LUZ v. NATIONAL AMNESTY COMMISSION

FACTS:

Jaime Beltran Luz was charged with illegal possession of firearms in July 1988. In March 2000, he applied for amnesty with the Local Amnesty Board for Metro Manila but was denied. The National Amnesty Commission (NAC) affirmed the denial and rejected the motion for reconsideration.

Petitioner had until December 7, 2002, a Saturday, to file a petition for review with the Court of Appeals. However, he filed a motion for a 15-day extension on December 9, 2002, which was granted by the Court of Appeals. Despite the extension, he failed to file the petition within the extended period.

Petitioner then filed a second motion for extension on December 26, 2002, requesting an additional 15 days to file the petition. However, the Court of Appeals denied the second motion, stating that it was filed out of time.

ISSUES:

  1. Whether the petitioner timely filed his second motion for extension of time to file his petition for review.

  2. Whether the Court of Appeals should have admitted the petitioner's petition for review in the interest of justice.

RULING:

  1. The Court ruled in favor of the Court of Appeals and held that the petitioner's second motion for extension of time to file his petition for review was filed out of time. The Court also held that the Court of Appeals was not obliged to admit the petitioner's petition for review in the interest of justice.

PRINCIPLES:

  • In computing any period of time prescribed or allowed by the rules or by order of the court, 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, Rule 22, 1997 Rules of Civil Procedure).

  • The ruling in A.M. No. 00-2-14-SC provides that any extension of time to file the required pleading should be counted from the expiration of the period regardless of whether the expiration date falls on a Saturday, Sunday, or legal holiday.

  • The Court is not obliged to admit a late filing of a petition for review even in the interest of justice.