Pagtalunan v. Manlapig
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a landholding located in Barangay Calumpang, Calumpit, Bulacan, with an area of 2,500 square meters. The Department of Agrarian Reform Adjudication Board (DARAB) previously decided to grant possession of this property to the landowner, Ricardo Manlapig, based on the finding that the tenant, Angel Pagtalunan, failed to pay lease rentals. 2. Procedural History: Following the DARAB's decision, the heir of the defendant tenant, Zenaida Pagtalunan, filed a petition for review with the Court of Appeals under Rule 43 of the 1997 Rules of Civil Procedure. The Court of Appeals, however, dismissed this petition. The dismissal was based on the deficiency in the Verification and Certification of Non-Forum Shopping, which was signed by only one of the petitioners without any showing of authorization to represent the co-petitioners. A subsequent motion for reconsideration was also denied by the Court of Appeals. 3. The Petition: This case reaches the Supreme Court via a petition for review on certiorari under Rule 45 of the Rules of Court. The petitioner seeks to challenge the Resolution of the Court of Appeals that dismissed their petition. The Supreme Court, in its review, found no reversible error in the appellate court's decision, emphasizing the strict enforcement of verification and certification requirements when multiple parties are involved. The Court also noted that the core issues of the case are factual, concerning the alleged non-payment of lease rentals, which are matters generally outside the scope of Supreme Court review.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for review on the ground of a defective Verification and Certification of Non-Forum Shopping. Whether the Court of Appeals erred in not resolving the factual issues regarding the alleged non-payment of lease rentals.
Ruling
The petition is DENIED. The resolution of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of the defective Verification and Certification of Non-Forum Shopping: The Supreme Court affirmed the Court of Appeals' dismissal of the petition. The Court reiterated its strict enforcement of the requirements for verification and certification of non-forum shopping under Section 5, Rule 7 of the Rules of Court. It emphasized that when there are multiple petitioners, a petition signed by only one is considered defective unless that signatory possesses express authorization from the other co-parties to represent them and execute the certification. The attestation in the certification requires personal knowledge from the affiant, which was not demonstrated in this case. The Court cited previous rulings in Philippine Valve Manufacturing Company v. NLRC and Loquias v. Office of the Ombudsman to support this strict adherence to procedural rules. On the issue of resolving factual matters: The Supreme Court held that the issues involved in the case were primarily factual, specifically concerning whether there was substantial evidence proving Angel Pagtalunan's failure to pay lease rentals. The Court reiterated the established principle that factual findings of administrative agencies, such as the DARAB, are generally accorded respect and finality by the courts. Consequently, the Supreme Court, not being a trier of facts, is not the proper forum to resolve such factual disputes. This principle was supported by citations to Sebastian v. Morales and Padunan v. Department of Agrarian Reform Adjudication Board.
Main Doctrine
A petition signed by only one of multiple petitioners is defective unless that petitioner is authorized to sign for and in behalf of the co-petitioners. Factual findings of administrative agencies are generally accorded respect by the courts.