9. A first aspect to consider is that, usually, the calculation of time limits in days should begin (dies a quo) on the subsequent working day. In this case, since the time limit was established on the basis of months, this rule does not apply. Time limits in months or years are calculated according to the calendar unit corresponding to the calendar day on which the period commenced, as agreed to simplify the calculation for the parties and for the courts. For example, if the time limit starts on the 5th, it will expire on the 5th day of the respective month or month-year. 10. However, from this other perspective and a fortiori, with regard to the day of expiry (dies ad quem) of the procedural time limit, the general rule must be to extend it to the following working day in cases when the date of expiry occurs on a non-working day (that is, a holiday or weekend). This, irrespective of the calculation of the time limit in days, months or years. 11. Precisely in the case of dates of expiry where the traditional calculation did not allow an extension – in other words, if the period expired on a non-working day – it was not extended until the following working day, but had to be brought forward to the previous working day; however, the actual tendency is to extend the period to the first working day. This is in the understanding that procedure should merely be an instrument, and not an end in itself, and that it should be simple. Also, it should be noted that the instant case does not refer to a lapsed period, or even to prescription, but to a simple procedural time limit in which the discussion of non-extension owing to a lapsed period does not exist. Therefore, it should not exist in these proceedings either. 12. If the Rules of Procedure are omissive in this regard – which is intentional, a truly eloquent silence, to avoid redundancy and innovation in the domestic law of the jurisdictional State – national laws are not. Even though the Rules of Procedure are silent in this respect, since they do not include a provision with regard to the day of expiry that can be used, we should not adopt the restrictive interpretation of expiry over a weekend, when the Court is not even functioning. Moreover, requiring the period to be brought forward to the previous working day is also an undesirable and unacceptable restriction for the comprehensive right to defense of the parties. 13. Logically, the expiry of the time limit can only occur on a working day, when the parties can use any of the formally established means to submit briefs. Article 26 of the Rules of Procedure provides for them expressly. Clearly some of the means of presenting briefs could not be used during weekends and holidays, simply because there would be no Court official to receive them. These are precisely the traditional forms of presentation, which are in person, by mail or courier. If the briefs reach their destination and cannot be delivered, it is reasonable to wait until the following day, when the Court officials and judges can act on them, and no delay has occurred. 14. Although at first glance, it could appear that the emphatic nature of the words “which may not be extended” expressly included in Article 36 – transcribed above in a footnote – refer to the expiry (dies ad quem) of the time limit, constituting a real obstacle to the extension when it falls on a holiday, in truth this interpretation is unsustainable because it is not coherent with the continental or even the universal procedural system. 15. The words “which may not be extended” mean that the time limit should not be extended by an agreement between the parties or the generosity of the Court (except in extremely exceptional cases that need not be discussed) since, according to Chiovenda’s classification, 3 it is a “strictly peremptory” time limit 4 that results in absolute preclusion and does not admit extension. 3 CHIOVENDA, Giuseppe. Instituciones de derecho procesal civil. Translated by Paolo Capitanio, Campinas (Brazil): Bookseller, 1998. 3v., pp. 12/14. 4 Chiovenda distinguishes three types of time limits: (a) strictly peremptory; (b) extendible, and (c) comminatory or simple.