Practice question
An administrative appeal provision grants six months, without referring to six calendar months or naming particular months, and no special rule applies. A party insists it necessarily means the same calendar date six months later because a year is twelve calendar months. What distinction does PhilHealth v. COA preserve?
- Every six-month period is automatically one-half of a calendar year
- The statutory definition of a month is irrelevant
- An unspecified month becomes thirty-one days in summer
- The unspecified-month rule remains thirty days per month, so six such months are 180 days
- The deadline may be selected after filing
Legal references
- https://lawphil.net/executive/execord/eo1987/eo_292_1987.html — EO 292, Book I, Chapter VIII, section 31
- https://lawphil.net/judjuris/juri2007/aug2007/gr_162155_2007.html — CIR v. Primetown Property Group, Inc., G.R. No. 162155, August 28, 2007
- https://lawphil.net/judjuris/juri2018/sep2018/gr_222838_2018.html — PhilHealth v. COA, G.R. No. 222838, September 4, 2018
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