Porto v. Grant Institute of Trade & Technology, Inc.
REITERATIONFacts
The Antecedents: Seven complainants, including petitioners, filed consolidated complaints for Estafa and Falsification against Grant Institute of Trade & Technology, Inc. (GITT) and its Board of Directors. They alleged that GITT, managed by the private respondents, offered a Cruise Ship Management Course without the necessary authority from the Technical Education & Skills Development Authority (TESDA). GITT, through its Board of Directors, asserted that the complaints were baseless and intended for harassment, and that they acted in good faith. Procedural History: The Office of the City Prosecutor (OCP) of San Pablo City recommended the filing of Informations for Estafa but dismissed the Falsification charges, deeming them absorbed in Estafa. The Office of the Regional Prosecutor (ORP) for Region IV reversed the OCP's resolution, ordering the withdrawal of the Informations, finding that GITT and its Board acted in good faith despite the lack of TESDA authority, as the application was entrusted to the registrar who failed to secure it. The Court of Appeals (CA) dismissed petitioners' Joint Petitions for Certiorari outright due to several procedural deficiencies, including failure to pay docket fees, submit verification and certification against forum-shopping, and indicate proper addresses. The CA later denied petitioners' motion for reconsideration, adding that petitioners failed to exhaust administrative remedies by not appealing to the Secretary of Justice. The Petition: Petitioners assail the CA's dismissal, arguing that the CA erred in dismissing their petitions outright and in ruling that they failed to exhaust administrative remedies. They contend that DOJ Department Circular No. 70-A delegated final authority to Regional State Prosecutors to resolve appeals, making their resort to certiorari proper after the ORP's resolution.
Issue(s)
Whether or not the Court of Appeals erred in dismissing the Joint Petitions for Certiorari outright due to procedural deficiencies. Whether or not the Court of Appeals erred in dismissing the Joint Petitions for Certiorari on the ground of failure to exhaust the DOJ-NPS appellate process, and whether the CA's reasoning regarding estafa cases was correct.
Ruling
The Petition is denied. The Resolution dated November 20, 2020, of the Court of Appeals is affirmed, while its Resolution dated June 14, 2021, is reversed and set aside.
Ratio Decidendi
On the first issue (outright dismissal by the CA): The Supreme Court affirmed the CA's initial dismissal of the Joint Petitions for Certiorari. The Court found multiple procedural deficiencies that warranted the outright dismissal. These included petitioners' failure to pay the requisite docket fee, failure to attach and submit the sworn verification and certification against forum-shopping, failure to indicate their actual and complete addresses, failure to furnish the ORP with copies of the petitions, and failure to sign the petitions in accordance with the Rules of Court. The Court found no valid excuse for these procedural lapses, particularly the failure to pay docket fees, despite the COVID-19 pandemic, as courts were mandated to operate. The Court emphasized that liberality in applying procedural rules is not warranted when a party has every opportunity to comply, especially with jurisdictional requirements. The Court also noted that the absence of a proper verification and certification against forum-shopping is fatal to an original petition before the CA. On the second issue (failure to exhaust administrative remedies): The Supreme Court found that the CA erred in ruling that petitioners failed to exhaust administrative remedies. The Court clarified that DOJ Department Circular No. 70-A, as reiterated in subsequent circulars, delegated the final resolution of appeals from Provincial/City Prosecutors' resolutions to Regional State Prosecutors for cases cognizable by first-level trial courts outside the National Capital Region. Therefore, after the ORP's resolution denying the motion for reconsideration, the next available remedy was a petition for certiorari before the Court of Appeals, not an appeal to the Secretary of Justice. The Court noted that the CA's reasoning that estafa cases were not cognizable by first-level courts was outdated due to amendments in the Revised Penal Code and the Judiciary Reorganization Act. However, despite this error by the CA, the Supreme Court sustained the dismissal of the petitions based on the procedural deficiencies previously discussed.
Main Doctrine
The Court of Appeals correctly dismissed the petitions outright due to multiple procedural deficiencies, including failure to pay docket fees, submit required verification and certification against forum-shopping, and indicate proper addresses. While the CA erred in its reasoning regarding the exhaustion of administrative remedies, the dismissal based on procedural defects is sustained.