Caballes v. Court of Appeals
REITERATIONFacts
The Antecedents: This case originated from a complaint filed by petitioner Jesus Caballes before the Regional Agrarian Reform Adjudicator (RARAD) of Tagum City, against respondents Corazon Adolfo Calderon and others. The RARAD initially ruled in favor of the petitioner. However, private respondent Corazon Adolfo Calderon appealed this decision to the Department of Agrarian Reform Adjudication Board (DARAB). Procedural History: The DARAB, in its Decision dated December 26, 2019, reversed the RARAD's ruling. Petitioner's motion for reconsideration was subsequently denied by the DARAB in a Resolution dated December 14, 2020. Petitioner received this denial on February 11, 2021. Thereafter, on February 26, 2021, petitioner filed a petition for review with the Court of Appeals (CA) via registered mail. The CA, in a Minute Resolution dated March 25, 2021, dismissed the petition outright due to several procedural defects. Petitioner's motion for reconsideration, which included an amended petition attempting to correct these defects, was denied by the CA in a Resolution dated June 24, 2022. The Petition: Petitioner seeks certiorari under Rule 65 of the Rules of Court, assailing the CA's dismissal of his petition for review. He argues that the CA committed grave abuse of discretion by dismissing his appeal on procedural grounds, including alleged belated filing, failure to attach certified true copies of assailed decisions, omission of material dates, lack of competent evidence of identity, an outdated IBP official receipt number for his counsel, and failure to state the addresses of the private respondents. The Supreme Court is asked to determine if these procedural defects warranted the outright dismissal of the petition for review, or if substantial compliance and the interest of justice should have prevailed.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction in ruling that the petitioner's petition for review was belatedly filed. Whether the Court of Appeals committed grave abuse of discretion in dismissing the petition for review for failure to attach certified true copies of the assailed decisions. Whether the Court of Appeals committed grave abuse of discretion in dismissing the petition for review for failure to indicate the date of receipt of the assailed decision and filing of the motion for reconsideration thereto. Whether the Court of Appeals committed grave abuse of discretion in dismissing the petition for review for failure to show competent evidence of identity by attaching a photocopy of the voter's ID. Whether the Court of Appeals committed grave abuse of discretion in dismissing the petition for review for indicating an outdated Integrated Bar of the Philippines (IBP) Official Receipt number of the counsel. Whether the Court of Appeals committed grave abuse of discretion in dismissing the petition for review for failure to state the addresses of private respondents. Whether the Court of Appeals committed grave abuse of discretion in denying, after the lapse of more than a year, the petitioner's motion for reconsideration with attached amended petition for review.
Ruling
The petition is granted. The Minute Resolution dated March 25, 2021 and the Resolution dated June 24, 2022 of the Court of Appeals are reversed and set aside. The case is remanded to the Court of Appeals for the resolution of petitioner Jesus Caballes' petition for review.
Ratio Decidendi
On the issue of belated filing: The Court held that the CA committed grave abuse of discretion in ruling that the petition for review was belatedly filed. Section 3, Rule 13 of the Rules of Court clearly states that the date of mailing, as shown by the post office stamp or registry receipt, shall be considered the date of filing. The registry receipts showed the petition was mailed on February 26, 2021, which was the last day of the reglementary period. The CA's failure to observe this basic rule constituted grave abuse of discretion. This error was further highlighted when the CA ignored the registry receipts attached to the motion for reconsideration and insisted on its erroneous finding. On the failure to attach certified true copies: The Court found that the petitioner's filing of an amended petition with certified true copies attached to his motion for reconsideration constituted substantial compliance with Section 6(c), Rule 43. Analogous to the ruling in Duremdes v. Jorilla, this rectified the defect and should not have been a ground for outright dismissal. On the failure to state material dates: The Court reiterated its ruling in Victoriano v. Dominguez and Capin-Cadiz v. Brent Hospital and Colleges, Inc. that the failure to indicate the date of receipt of the assailed decision is not fatal, as the important date is the receipt of the resolution denying the motion for reconsideration. Since the petitioner indicated the date of receipt of the DARAB resolution denying his motion for reconsideration and filed his petition within the reglementary period, he substantially complied with Section 6(d), Rule 43. The other material dates could be gleaned from the records. On the failure to attach a photocopy of the ID: The Court clarified that Section 12, Rule II of the 2004 Rules on Notarial Practice lists what constitutes competent evidence of identity, and a voter's ID is included. The rule does not require a photocopy of the ID to be attached to the petition, nor does it render a petition dismissible for such failure. The ruling in Heirs of Amada Zaulda v. Zaulda was cited, emphasizing that attachment of a photocopy is not required and that verification is a formal, not jurisdictional, requirement. On the outdated IBP Official Receipt: The Court noted that this inadvertent omission was rectified by the counsel in the amended petition. Citing Go v. Sunbanun and Victoriano v. Dominguez, the Court held that such minor defects, when immediately rectified, are not fatal and should not prejudice the client, especially when the counsel's IBP number was updated in subsequent pleadings. On the failure to indicate respondents' addresses: The Court observed that the CA did not cite any specific rule requiring the indication of private respondents' addresses, only their names. While the requirement is founded on justice and fair play, the petitioner's failure was by inadvertence, as the counsel's address was provided, and copies were sent to the counsel. The mistake was rectified in the amended petition, and private respondents were not prejudiced, thus constituting substantial compliance. On the delay in resolving the motion for reconsideration: Given that the Supreme Court granted the petition and remanded the case for resolution on the merits, it deemed further discussion on this issue unnecessary.
Main Doctrine
The Court reiterated that the date of mailing of pleadings, as shown by the post office stamp or registry receipt, is considered the date of filing. Failure to strictly comply with procedural rules may be excused in the interest of substantial justice, especially when the defects are minor, rectified promptly, and do not prejudice the opposing party.