Good Earth Enterprises, Inc. v. Garcia
REITERATIONFacts
The Antecedents: Petitioner Good Earth Enterprises, Inc. (GEEI) is the registered owner of a parcel of land in San Dionisio, Sucat, Parañaque City, as affirmed by this Court in Baltazar v. Court of Appeals. Following the finality of that decision and during execution proceedings, GEEI discovered that respondents, who were sub-lessees from a lessee of a losing party in the Baltazar case, were occupying portions of the subject property. GEEI tolerated their continued stay during ongoing legal disputes. After GEEI prevailed in these disputes, it sent demand letters in May and July 2011 for the respondents to vacate the property, which were ignored. Procedural History: In response to the respondents' failure to vacate, GEEI filed an Amended Complaint for ejectment on September 29, 2011. The Metropolitan Trial Court (MeTC) of Parañaque City, Branch 08, ruled in favor of GEEI on March 22, 2013, ordering the respondents to vacate, pay compensation for their use and occupation, and pay attorney's fees. The Regional Trial Court (RTC) of Parañaque City, Branch 258, affirmed the MeTC's decision on July 27, 2016. However, the Court of Appeals (CA) reversed and set aside the RTC's ruling on May 18, 2017, dismissing GEEI's complaint on a procedural ground. The Petition: GEEI filed this petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's Decision and Resolution. The CA dismissed GEEI's unlawful detainer complaint solely on the procedural ground that the verification and Certificate of Non-Forum Shopping were not properly authorized by GEEI, as the Secretary's Certificate proving the authority of the signatory, Mr. Stephen Hontiveros, was not initially attached. GEEI argues that the CA erred in dismissing the case on this basis, asserting that it had belatedly submitted the Secretary's Certificate, which constituted substantial compliance and ratified the signatory's authority.
Issue(s)
Whether the Court of Appeals (CA) correctly dismissed petitioner's complaint for unlawful detainer on a purely procedural ground, specifically the non-compliance with the rules on verification and certification against forum shopping. Whether the belated submission of a Secretary's Certificate constitutes substantial compliance.
Ruling
The petition is meritorious. The Court reversed and set aside the Decision and Resolution of the Court of Appeals and remanded the case to the CA for resolution on the merits.
Ratio Decidendi
On the issue of whether the CA correctly dismissed the complaint on procedural grounds: The Court ruled that the CA erred in dismissing the complaint solely on the ground that Mr. Stephen Hontiveros was not duly authorized to sign the verification and Certificate of Non-Forum Shopping (CNFS). A review of the records showed that petitioner had belatedly submitted a Secretary's Certificate confirming Hontiveros' authority to file actions and sign documents on its behalf. This certificate was filed with a Manifestation explaining the omission was due to inadvertence and oversight, and it was marked as part of the records. The Court emphasized that case law provides that a party's belated submission of a Secretary's Certificate constitutes substantial compliance with the rules. Such submission operates to ratify and affirm the authority of the delegate to represent the party before the courts. Therefore, Hontiveros was duly authorized, and the CA's dismissal on this ground was erroneous. On the issue of substantial compliance: The Court held that the belated submission of the Secretary's Certificate constituted substantial compliance. The Court cited existing jurisprudence that allows for the ratification of a delegate's authority through the subsequent submission of the required authorization, even if filed late. This principle is rooted in the idea that the intent of the rules on verification and CNFS is to ensure good faith and prevent forum shopping, which is sufficiently addressed when the authority is later confirmed and the omission is explained as mere inadvertence. The CA's observation that petitioner did not attempt to comply at all was contradicted by the record of the belated submission and explanation.
Main Doctrine
The belated submission of a Secretary's Certificate, confirming the authority of the signatory to represent the corporation, constitutes substantial compliance with the rules on verification and certificate against forum shopping, and operates to ratify the delegate's authority.