Neypes vs.

CA
Facts:
The case involves petitioners Domingo Neypes, Luz Faustino, Rogelio Faustino, Lolito Victoriano,
Jacob Obania, and Domingo Cabacungan, who filed an action for annulment of judgment and
titles of land, as well as reconveyance and reversion with a preliminary injunction against the
Bureau of Forest Development, Bureau of Lands, Land Bank of the Philippines, and the heirs of
Bernardo del Mundo (Fe, Corazon, Josefa, Salvador, and Carmen).
The case was initiated in the Regional Trial Court, Branch 43, of Roxas, Oriental Mindoro. During
the proceedings, various motions were filed, including a motion by the petitioners to declare
the Bureau of Lands and Bureau of Forest Development in default due to their failure to file an
answer, and motions to dismiss filed by the respondent heirs and the Land Bank of the
Philippines.
On May 16, 1997, the trial court, presided over by Judge Antonio N. Rosales, granted the
petitioners' motion to declare the Bureau of Lands and Bureau of Forest Development in default
but denied it against the heirs of del Mundo due to improper service of summons. The Land
Bank's motion to dismiss was denied, as were the heirs' motion based on prescription.
Subsequently, the heirs filed a motion for reconsideration regarding the denial of their motion
to dismiss, arguing that the trial court could resolve the issue of prescription based on the
complaint's allegations. On February 12, 1998, the trial court dismissed the petitioners'
complaint on the grounds of prescription. The petitioners received this order on March 3, 1998,
and filed a motion for reconsideration on March 18, 1998.
On July 1, 1998, the trial court dismissed the motion for reconsideration, which the petitioners
received on July 22, 1998. They filed a notice of appeal on July 27, 1998, and paid the appeal
fees on August 3, 1998. However, the trial court denied the notice of appeal, stating it was filed
eight days late. The petitioners then filed a motion for reconsideration, which was also denied
on September 3, 1998. They subsequently filed a petition for certiorari and mandamus before
the Court of Appeals, claiming their notice of appeal was timely. The Court of Appeals dismissed
the petition on September 16, 1999, ruling that the appeal period should have started from the
February 12, 1998 order, making the appeal tardy. The petitioners filed a motion for
reconsideration, which was denied on January 6, 2000.
Issue:
1. Did the Court of Appeals err in dismissing the petitioners' petition for certiorari and
mandamus and affirming the trial court's dismissal of the petitioners' appeal?
2. Was the petitioners' appeal filed out of time, considering the date they received the
final order?
3. Did the Court of Appeals err in interpreting the term "final order" in the context of the
appeal period?
Ruling:
1. The Supreme Court granted the petition, reversing the Court of Appeals' decision and
setting it aside.
2. The petitioners' appeal was deemed timely filed within the fresh period of 15 days
from the receipt of the final order.
3. The term "final order" was interpreted to refer to the July 1, 1998 order denying the
motion for reconsideration.
Ratio:
The Supreme Court emphasized that the right to appeal is a statutory privilege that must be
exercised in accordance with the law. The Court clarified that the appeal period is governed
by both statute and procedural rules, specifically BP 129 and Rule 41, Section 3 of the 1997
Rules of Civil Procedure, which stipulate a 15-day period to appeal from the notice of a final
order.
The Court determined that the July 1, 1998 order denying the motion for reconsideration
constituted the "final order" that triggered the appeal period, not the earlier February 12,
1998 order dismissing the complaint.
The Court ruled that the petitioners had filed their notice of appeal within the fresh 15-day
period from the receipt of the July 1 order, which is July 22, thus making their appeal timely.
END

Doctrine:
The Supreme Court established a pivotal doctrine that the "final order" which triggers the
appeal period can consist of either the judgment being appealed or the order denying a
subsequent motion for reconsideration. This emphasizes the importance of considering the
procedural rights of litigants and acknowledges the substantial justice that must accompany
judicial processes. This "fresh period rule" must apply uniformly across various appeal situations
to avoid undue hardship from technicalities, thus providing a clearer framework for the
operations of trial courts and litigants.
The Court also noted that the use of "or" in the rules allows for the appeal period to be counted
from either the judgment or the final order, reinforcing the notion that the July 1 order was
indeed the final order for the purposes of appeal. The Court's decision aimed to balance the
strict enforcement of procedural rules with the need to ensure that litigants have a fair
opportunity to seek justice, thereby allowing the petitioners' appeal to proceed.

JULY 22- Denial of motion for recon

Facts:
The case involves Jose “Pepe” Sanico as the petitioner and the People of the Philippines, along
with private respondent Jennifer S. Tenio.
The events leading to this case began when Sanico and his co-accused, Marsito Batiquin, were
charged with trespassing (Criminal Case No. 3433-CR) and theft of minerals (Criminal Case No.
3434-CR) in the Municipal Circuit Trial Court (MCTC) of Catmon-Carmen-Sogod, Cebu. On April
2, 2009, the MCTC convicted both accused in Criminal Case No. 3434-CR, sentencing them to
imprisonment ranging from six months and one day to two years and four months, along with a
fine of P10,000 each. They were also ordered to pay substantial damages to the private
complainant, Tenio. However, in Criminal Case No. 3433-CR, they were acquitted of trespassing
due to insufficient evidence.
On April 22, 2009, Sanico's counsel filed a notice of appeal. The Regional Trial Court (RTC) of
Danao City subsequently ordered Sanico to submit a memorandum on appeal on January 5,
2010. Sanico failed to comply, leading the RTC to dismiss his appeal on March 16, 2010, citing
the lack of a memorandum as grounds for dismissal. Sanico's motion for reconsideration was
denied on June 1, 2010, due to lack of verification and justifiable reasons for his failure to file
the memorandum. Sanico then filed a petition for review with the Court of Appeals (CA) on
June 23, 2010, contesting the dismissal of his appeal. The CA denied this petition on April 14,
2011, citing multiple procedural defects, including non-payment of docket fees and lack of
proper proof of service. Sanico's subsequent motion for reconsideration was also denied on
September 15, 2011. The RTC had already authorized the entry of judgment against Sanico,
leading to the execution of the decision and the sale of his properties.
Issue:
1. Did the Court of Appeals err in holding against Sanico the negligence of his former
counsel, thereby depriving him of his right to appeal?
2. Did the Court of Appeals commit reversible error in not nullifying the RTC's order
dismissing the appeal for failure to file a memorandum?
3. Did the Court of Appeals err in not remanding the case to the RTC for review of the legal
infirmities in the MCTC's judgment?
Ruling:
The Supreme Court granted the petition for review on certiorari, reversing and setting aside the
resolutions of the Court of Appeals. The Court annulled the RTC's orders dismissing Sanico's
appeal and quashed the entry of judgment against him. The case was remanded to the RTC for
further proceedings.
Ratio:
The Supreme Court found that the RTC had misapplied the Rules of Court by dismissing Sanico's
appeal solely for failing to file a memorandum on appeal. The Court emphasized that the
failure to file such a memorandum is a ground for dismissal only in civil cases, not in criminal
cases. In criminal appeals, the RTC is required to decide based on the entire record and any
memoranda filed, regardless of whether the appellant submitted a memorandum. The Court
noted that Sanico had timely perfected his appeal by filing a notice of appeal, and thus, he was
entitled to have his case reviewed by the RTC.
The Court criticized the CA for failing to recognize the RTC's error and for focusing instead on
the procedural defects in Sanico's petition for review. The Court highlighted that the negligence
of Sanico's counsel should not bind him, especially when such negligence resulted in a denial of
his right to appeal. The Court underscored the importance of safeguarding the right to appeal as
an essential component of due process, stating that the legitimate interests of the petitioner
should not be sacrificed due to technicalities. The case was remanded to the RTC for a proper
review of the conviction, restoring Sanico's situation prior to the wrongful dismissal of his
appeal.
END
Timeline
Sanico received the order of dismissal from the Municipal Circuit Trial Court (MCTC) on April 2,
2009, when he was convicted of theft. The timeline of events following that includes:
- April 22, 2009: Sanico's counsel filed a notice of appeal in the MCTC.
- January 5, 2010: The RTC ordered Sanico to file his memorandum on appeal.
- March 16, 2010: The RTC dismissed Sanico's appeal due to his failure to file the memorandum
on appeal.
- April 26, 2010: Sanico, through Atty. Dennis Caete, filed a motion for reconsideration regarding
the dismissal of his appeal.
- June 1, 2010: The RTC denied the motion for reconsideration due to lack of verification and
affidavit of merit.
- June 23, 2010: Sanico, through Atty. Caete, filed a petition for review in the CA contesting his
conviction and the dismissal of his appeal.
- April 14, 2011: The CA dismissed Sanico's petition for review due to multiple procedural
deficiencies, including non-payment of docket fees and lack of proper proof of service.
- September 15, 2011: The CA denied Sanico's motion for reconsideration of the dismissal of his
petition for review.
Macaslang vs. Zamora

Facts:
The case involves Dolores Adora Macaslang as the petitioner and Renato and Melba Zamora as
the respondents.
The events leading to the case began on March 10, 1999, when the respondents filed a
complaint for unlawful detainer against the petitioner in the Municipal Trial Court in Cities
(MTCC) of Danao City. The respondents alleged that the petitioner sold them a residential land
located in Sabang, Danao City, and subsequently requested to live in the house on the property,
promising to vacate once she found a new residence. However, after a year, the petitioner failed
to vacate despite the respondents' demands. The MTCC declared the petitioner in default due
to her failure to file an answer to the complaint, leading to a judgment on September 13, 1999,
ordering her to vacate the premises and pay attorney's fees and monthly rentals. The petitioner
appealed this decision to the Regional Trial Court (RTC), which dismissed the complaint on May
18, 2000, for failure to state a cause of action. The respondents then appealed to the Court of
Appeals (CA), which reversed the RTC's decision on July 3, 2002, reinstating the MTCC's ruling.
The petitioner subsequently filed a petition for review with the Supreme Court.
Issue:
1. Is the Regional Trial Court (RTC) limited to the errors assigned in the appeal
memorandum when reviewing a decision from the Municipal Trial Court (MTC), or can
it decide based on the entire records of the case?
2. Does a valid cause of action exist in an unlawful detainer case where there was no prior
demand to vacate?
3. Did the Court of Appeals err in reinstating the MTC's decision despite procedural lapses
in the trial?
Ruling:
The Supreme Court granted the petition for review, ruling that:
1. The RTC, as an appellate court, is not limited to the assigned errors in the appeal
memorandum and can consider the entire record of the proceedings.
2. The complaint for unlawful detainer sufficiently stated a cause of action, as it included
allegations of demand to vacate.
 3. The CA's decision to reinstate the MTC's ruling was incorrect, as the respondents'
demand to vacate was valid, and the RTC's dismissal of the complaint was upheld due to
the lack of a cause of action.
Ratio:
The Supreme Court explained that the RTC, in its appellate capacity, is empowered to review
the entire record of the case, as stipulated in Section 18 of Rule 70 of the Rules of Court. This
provision allows the RTC to consider issues not explicitly raised in the appeal memorandum,
ensuring a comprehensive review of the case.
The Court also clarified that a complaint for unlawful detainer must allege that the
defendant's possession was initially lawful and became unlawful upon demand to vacate. The
CA's assertion that the RTC could not address unassigned issues was deemed erroneous, as
the RTC's findings on the lack of cause of action were necessary for a just resolution of the
case. Furthermore, the Court noted that the respondents had indeed made a valid demand to
vacate, which was sufficient to establish a cause of action for unlawful detainer. Ultimately,
the Court upheld the RTC's conclusion that the respondents' claim was flawed, as the
evidence suggested that the transaction was an equitable mortgage rather than a sale, thus
affirming the petitioner's right to retain possession of the property.
END
Section 18 of Rule 70 of the Rules of Court states that the judgment or final order from the
Municipal Trial Court (MTC) is appealable to the appropriate Regional Trial Court (RTC), which
shall decide the case based on the entire record of the proceedings in the court of origin and
any memoranda or briefs submitted by the parties or required by the RTC. This provision
emphasizes that the RTC is not limited to the errors assigned in the appeal but can review the
entire record.

The unlawful detainer case was dismissed by the Supreme Court due to a lack of cause of
action, despite the existence of a valid demand to vacate. The Court determined that the
evidence suggested the transaction between the parties was an equitable mortgage rather than
a sale, undermining the respondents' claim of ownership. This finding indicated that the
respondents did not have the right to possess the property, which is essential for a valid cause
of action in an unlawful detainer case. Thus, the dismissal was based on the respondents' failure
to establish their legal right to possession, not on the validity of the demand to vacate.
De Vera vs. Spouses Santiago

Facts:
The case involves a petition for review on certiorari filed by Wilfredo De Vera and several
other petitioners against the spouses Eugenio Santiago, Sr. and Esperanza H. Santiago, among
others, as respondents.
The events leading to the case began on February 14, 2000, when the petitioners filed an
action for reconveyance of ownership or possession with damages against the respondents in
the Municipal Trial Court (MTC) of Bolinao, Pangasinan, which was docketed as Civil Case No.
939. The petitioners claimed ownership of portions of a subdivided land located at Barangay
Patar, Bolinao, Pangasinan, specifically Lot No. 7303, Cad. 559-D, with an area of approximately
265,342 square meters. They asserted that they and their predecessors had been in actual and
continuous possession of their respective portions since 1967, without disturbance. However,
they later discovered that the land was covered by Free Patent Titles in the names of the
respondents, which they alleged were obtained through manipulation, misrepresentation,
fraud, and deceit. The petitioners sought to be declared as the absolute owners of Lot 7303
and requested the reconveyance of the land, along with damages.
In response, the respondents denied the allegations and claimed ownership of the land,
asserting that their titles were acquired legally. They contended that the MTC lacked
jurisdiction over the case since the assessed value of the land exceeded P20,000.00, placing it
within the exclusive original jurisdiction of the Regional Trial Court (RTC). The MTC ruled in
favor of the respondents on November 9, 2001, dismissing the petitioners' complaint and
declaring the respondents as the lawful owners of the land. The petitioners then appealed to
the RTC, which reversed the MTC's decision on June 14, 2002, declaring the respondents' Free
Patent Titles void and ordering them to reconvey the land to the petitioners. The respondents
subsequently filed a petition for review with the Court of Appeals (CA), which granted the
petition on May 29, 2007, annulling the decisions of both the RTC and the MTC for lack of
jurisdiction. The CA's ruling was upheld in a resolution dated August 22, 2007, prompting the
petitioners to seek a review from the Supreme Court.
Issue:
1. Did the Court of Appeals err in annulling the decision of the Regional Trial Court for
lack of jurisdiction?
Ruling:
The Supreme Court granted the petition for review on certiorari, reversing and setting aside the
decisions of the Court of Appeals. The case was remanded to the CA for the prompt resolution
of the factual issues raised in the respondents' petition for review of the RTC's decision.
Ratio:
The Supreme Court held that jurisdiction over the subject matter of a case is conferred by law
and determined by the allegations in the complaint. The Court clarified that while the MTC
lacked jurisdiction over the case due to the assessed value of the property exceeding
P20,000.00, the RTC correctly assumed jurisdiction on appeal. Under Section 8, Rule 40 of the
Rules of Court, if a lower court tried a case on the merits despite lacking jurisdiction, the RTC
may still decide the case if it has original jurisdiction. The Court emphasized that the RTC's
appellate jurisdiction over cases decided by the MTC is not contingent on the amount involved.
Therefore, the CA erred in nullifying the RTC's decision for lack of jurisdiction, as the RTC had
the authority to review the case and should have resolved the factual issues raised by the
respondents.
Lim vs. Lim

Facts:
The case involves Ronald Geralino M. Lim (petitioner) and Edwin M. Lim (respondent), with the
events taking place in Iloilo City, Philippines.
The legal proceedings began when Ronald filed a complaint for grave threats against his brother
Edwin on November 11, 2012. The Office of the City Prosecutor subsequently filed an
Information against Edwin in the Municipal Trial Court in Cities, Branch 5, Iloilo City. The charge
stemmed from Edwin allegedly threatening Ronald with phrases such as "Pus-on ko ulo mo!" (I
will smash your head!) and "Patyon ta ikaw" (I will kill you). During the arraignment, Edwin
pleaded not guilty, and the case was referred to the Philippine Mediation Center, which
ultimately failed to yield a settlement, leading to a return to court.
The pre-trial was initially set for August 12, 2013, but was postponed due to the absence of
Ronald and his counsel. Subsequent rescheduling occurred, with the pre-trial finally set for
November 21, 2013. On that date, the prosecution requested to submit the Judicial Affidavits of
its witnesses, citing a failure to submit them earlier "for whatever reason." Despite opposition
from Edwin's counsel, the Municipal Trial Court allowed the late submission, granting the
prosecution until 5:00 PM that day to comply. Edwin filed a motion for reconsideration, arguing
that the prosecution had waived its right to submit the affidavits due to the late filing. The
Municipal Trial Court denied this motion but imposed a fine on the prosecution for its failure to
comply with the Judicial Affidavit Rule.
On January 29, 2014, Edwin filed a Petition for Certiorari and Prohibition with the Regional Trial
Court, claiming that the Municipal Trial Court had committed grave abuse of discretion by
allowing the belated submission of the Judicial Affidavits. The Regional Trial Court ruled in favor
of Edwin on June 6, 2014, declaring that the Municipal Trial Court had indeed committed grave
abuse of discretion. The prosecution and Ronald subsequently filed a motion for
reconsideration, which was denied on August 27, 2014. This led to the filing of a Petition for
Review on Certiorari before the Supreme Court on September 29, 2014.
Issue:
 1. Did the Regional Trial Court acquire jurisdiction over petitioners Ronald Geralino M. Lim
and the People of the Philippines?
2. Was the Petition for Certiorari and Prohibition the proper remedy to question the
November 21, 2013 Order of the Municipal Trial Court in Cities?
3. Did the Municipal Trial Court in Cities commit grave abuse of discretion in allowing the
belated submission of the Judicial Affidavits?
Ruling:
1. The Supreme Court ruled that the Regional Trial Court did acquire jurisdiction over the
petitioners.
2. The Court held that the Petition for Certiorari and Prohibition was the proper remedy to
question the Municipal Trial Court's order.
3. The Court affirmed that the Municipal Trial Court committed grave abuse of discretion in
allowing the belated submission of the Judicial Affidavits.
Ratio:
The Supreme Court clarified that in petitions for certiorari under Rule 65 of the Rules of Court,
summons is not required to be served on the respondents, as the court only needs to
determine if the petition is sufficient in form and substance. The Court noted that the
petitioners had voluntarily submitted to the court's jurisdiction by participating in the
proceedings, despite their claims of improper service.
Regarding the remedy, the Court emphasized that the remedies of appeal and certiorari are
mutually exclusive. Since the Municipal Trial Court's order allowing the belated submission of
Judicial Affidavits was an interlocutory order, the proper remedy was indeed a petition for
certiorari, as it addressed grave abuse of discretion rather than a mere error of judgment.
The Court further reinforced the importance of adhering to the Judicial Affidavit Rule, which
mandates that the prosecution must submit the Judicial Affidavits of its witnesses at least five
days before the pre-trial. The prosecution's justification for the late submission, described as
"for whatever reason," was deemed insufficient to warrant a deviation from the established
rules. The Municipal Trial Court's failure to enforce this rule constituted grave abuse of
discretion, justifying the Regional Trial Court's decision to set aside the earlier orders and
expunge the belatedly submitted Judicial Affidavits from the records.
Cagang vs. Sandiganbayan

Facts:
The case involves Cesar Matas Cagang (Petitioner) against the Sandiganbayan, Fifth Division,
Quezon City, the Office of the Ombudsman, and the People of the Philippines (Respondents).
The events leading to this case began on February 10, 2003, when the Office of the
Ombudsman received an anonymous complaint alleging graft and corruption involving public
officials in Sarangani Province, specifically Amelia May Constantino, Mary Ann Gadian, and Joy
Tangan. The complaint was referred to the Commission on Audit (COA) for investigation. The
COA's audit report, submitted on December 31, 2002, revealed significant embezzlement of
public funds amounting to millions, leading to a Joint Order from the Ombudsman on
September 30, 2003, which recommended filing criminal cases against numerous public
officials, including Cagang, who served as the Provincial Treasurer.
The preliminary investigation took several years, with the Ombudsman issuing a resolution
finding probable cause against Cagang and others on August 11, 2004. However, the actual
Informations against Cagang were only filed on November 17, 2011, leading to claims of
inordinate delay. Cagang filed a Motion to Quash/Dismiss the Informations, arguing that the
delay violated his constitutional rights to due process and speedy disposition of cases. The
Sandiganbayan denied his motions, leading to the filing of Petitions for Certiorari (G.R. Nos.
206438 and 206458) and subsequent motions regarding an Order of Arrest against him.
Issue:
1. Did the Sandiganbayan commit grave abuse of discretion in denying Cagang's Motion to
Quash/Dismiss based on the alleged inordinate delay in the preliminary investigation?
2. Was Cagang's right to speedy disposition of cases violated due to the delay in the filing
of the Informations?
3. Did the pendency of a petition for certiorari suspend the proceedings before the
Sandiganbayan?
Ruling:
 1. The Supreme Court ruled that the Sandiganbayan did not commit grave abuse of
discretion in denying Cagang's Motion to Quash/Dismiss.
2. The Court found that Cagang's right to speedy disposition of cases was not violated, as
he failed to timely assert this right during the preliminary investigation.
3. The Court held that the pendency of a petition for certiorari does not automatically
suspend the proceedings before the Sandiganbayan unless a temporary restraining order
or writ of preliminary injunction is issued.
Ratio:
The Supreme Court emphasized that the right to speedy disposition of cases is a constitutional
guarantee under Article III, Section 16 of the 1987 Constitution. However, the determination of
whether there was inordinate delay is not merely a mathematical calculation but requires a
contextual analysis of the facts and circumstances surrounding the case. The Court noted that
the complexity of the case, involving numerous individuals and transactions, justified the time
taken by the Ombudsman to resolve the complaints.
Furthermore, the Court highlighted that the accused must assert their right to speedy
disposition in a timely manner; failure to do so may be interpreted as a waiver of that right. In
this case, Cagang only invoked his right after the Informations were filed, which the Court found
to be too late. The Court also clarified that the pendency of a petition for certiorari does not
halt proceedings unless explicitly ordered, reinforcing the principle that the State has a duty to
prosecute cases without undue delay while also protecting the rights of the accused.
END
Rule 41 of the Rules of Court in the Philippines pertains to the dismissal of actions. It allows a
party to move for the dismissal of a case for various reasons, including failure to prosecute or
for lack of jurisdiction. In the context of the Cagang case, the principle of inordinate delay in the
preliminary investigation could invoke Rule 41, as the accused may argue for dismissal based on
the excessive delay in the resolution of their case by the Office of the Ombudsman. If the
accused can demonstrate that the delay is inordinate and unjustifiable, it may lead to the
dismissal of the case under this rule.
University of Mindanao, Inc. vs. Court of Appeals

Facts:
The case involves a petition for certiorari filed by the University of Mindanao, Inc. and several
individuals, including Dr. Guillermo P. Torres, Atty. Victor Nicasio P. Torres, and others, against
the Philippine Deposit Insurance Corporation (PDIC).
The events leading to this case began on August 31, 1990, when the Monetary Board issued a
resolution to close the Mindanao Savings and Loan Association (MSLA), placing it under the
receivership of the PDIC. Subsequently, on May 24, 1991, the Board ordered the liquidation of
MSLA and designated the PDIC as the liquidator. The PDIC filed a petition for assistance in the
liquidation process before the Regional Trial Court (RTC) of Davao City, which was granted on
September 29, 1991. Over the years, the RTC issued several orders directing the PDIC to
expedite the liquidation process, including a reminder for a liquidation plan and an inventory of
MSLA's assets.
On April 20, 2005, the RTC issued a resolution terminating the liquidation proceedings due to
the PDIC's failure to comply with mandatory requirements, including inventory and publication
of claims. The RTC ordered the PDIC to pay approved claims and deliver remaining MSLA assets
to the claimants. The PDIC appealed this resolution, and the Bangko Sentral ng Pilipinas (BSP)
also filed a notice of appeal. The RTC granted the PDIC an extension to file its record on appeal,
which was subsequently approved. However, the petitioners filed a motion to dismiss the PDIC's
appeal, arguing that the PDIC failed to comply with procedural requirements. The Court of
Appeals (CA) denied the motion to dismiss, leading to the present petition for certiorari.
Issue:
1. Did the Court of Appeals commit grave abuse of discretion in disregarding the
petitioners' motion to dismiss the appeal based on the PDIC's failure to comply with
procedural requirements?
2. Was the PDIC's notice of appeal defective, warranting dismissal of the appeal?
3. Did the Court of Appeals err in finding that the PDIC's record on appeal included the
necessary data showing its timely perfection?
4. Should the Court of Appeals have applied different jurisprudence in dismissing the
appeal?
Ruling:
The Supreme Court dismissed the petition, affirming the resolutions of the Court of Appeals
dated July 6, 2007, and October 24, 2007. The Court found no merit in the petitioners'
arguments regarding the procedural deficiencies claimed against the PDIC's appeal.
Ratio:
The Supreme Court ruled that the denial of a motion to dismiss is an interlocutory order and
cannot be the subject of a certiorari petition unless it is shown that the court acted without or
in excess of jurisdiction or with grave abuse of discretion. The Court emphasized that mere
abuse of discretion is insufficient; it must be grave and evident. The petitioners argued that the
CA disregarded the mandatory requirements of filing multiple copies of the approved record on
appeal. However, the Court clarified that the rules do not explicitly state that non-submission of
copies is a ground for dismissal. The Court also noted that the PDIC had substantially complied
with the requirements for the perfection of its appeal, as the CA had previously affirmed the
RTC's findings regarding the timeliness of the PDIC's filings.
Furthermore, the Court highlighted that the rules of procedure should be liberally construed to
promote justice rather than frustrate it. The petitioners' reliance on previous jurisprudence was
deemed misplaced, as the cases cited involved different circumstances. The Court reiterated
that the dismissal of appeals on purely technical grounds is discouraged, and judicial action
should prioritize the merits of the case over procedural technicalities. Thus, the CA's decision to
deny the motion to dismiss was upheld, and the petition was dismissed.

END
The Philippine Deposit Insurance Corporation (PDIC) faced several failures to comply with
procedural requirements during the liquidation process of the Mindanao Savings and Loan
Association (MSLA). These include:
1. Failure to Submit a Liquidation Plan: The RTC directed the PDIC to submit a liquidation plan,
which it did not comply with in a timely manner.
2. Non-compliance with RTC Orders: The PDIC was criticized for not adhering to the orders
issued by the RTC, which included directives to expedite the liquidation process and publish
notices for claimants.
3. Failure to Conduct Inventory: The RTC ordered the PDIC to take inventory of the MSLA's
assets, which was part of the procedural requirements that were not adequately fulfilled.
4. Failure to Publish Notices: The PDIC did not publish the necessary notices to inform
claimants, depositors, and creditors to file their claims, which is a critical step in the liquidation
process.
5. Defective Notice of Appeal: The PDIC's notice of appeal was argued to be defective for failing
to comply with formal requirements, such as not stating the timely filing of the notice of appeal
and other necessary details.
These failures contributed to the RTC's decision to terminate the liquidation proceedings due to
non-compliance with mandatory requirements.
United Interior Manggahan Homeowners Association vs. De Luna

Facts:
The case involves the United Interior Manggahan Homeowners Association, represented by its
President, Daniel Calilung (petitioner), against Hon. Ambrosio B. De Luna, Presiding Judge of the
Regional Trial Court (RTC) of Palawan and Puerto Princesa City - Branch 51, and the Spouses
Edilberto Villon and Helen Pe-Villon, now represented by their heirs (respondents).
The events leading to the case began in early 2000 when the petitioner filed a Complaint for
Specific Performance with a Prayer for the Issuance of a Temporary Restraining Order and
Preliminary Injunction with Damages against the respondents. After the petitioner presented its
case, the respondents filed a Manifestation and Motion to Dismiss on Demurrer to Evidence,
which the RTC granted on March 5, 2014, resulting in the dismissal of the petitioner's complaint.
The petitioner sought reconsideration, which was denied on May 6, 2014. Subsequently, the
petitioner filed a Notice of Appeal. The respondents then filed an Omnibus Motion to Strike
Out the Notice of Appeal, arguing that the petitioner lacked the authority from its Board of
Directors to file the appeal, as required by Section 12 of Republic Act No. 9904. They also
contended that the petitioner had not complied with certain reportorial requirements and
failed to show proof of payment of the necessary appeal fees. On September 19, 2014, the RTC
ordered the expungement of the Notice of Appeal from the records due to the lack of authority
from the Board of Directors. The petitioner’s motion for reconsideration, which included a
Board Resolution confirming Calilung's authority, was denied on December 12, 2014, leading to
the present petition for certiorari.
Issue:
The main issue for resolution is whether the RTC gravely abused its discretion in expunging the
petitioner’s Notice of Appeal from the records of the case.
Ruling:
The Supreme Court granted the petition, setting aside the RTC's Orders dated September 19,
2014, and December 12, 2014, and directed the RTC to give due course to the petitioner’s
Notice of Appeal.
Ratio:
The Court found that the RTC's expungement of the Notice of Appeal constituted grave abuse of
discretion. It clarified that under Section 1, Rule 65 of the Rules of Court, a certiorari petition is
appropriate when a tribunal acts without or in excess of its jurisdiction or with grave abuse of
discretion. The Court noted that the RTC's order effectively disallowed the appeal, which is a
situation where a certiorari action is warranted. The Court emphasized that the mere filing of a
Notice of Appeal does not automatically divest the trial court of its jurisdiction, as the appeal is
perfected only when the period for other parties to appeal has expired. The Court also
highlighted that a board resolution authorizing a representative to file a Notice of Appeal is not
a requirement under the Rules, as a Notice of Appeal is not a pleading that necessitates such
documentation. Furthermore, the Court pointed out that the RTC's insistence on proof of
payment of appeal fees was unfounded, given its prior acknowledgment that the fees had been
paid within the reglementary period. The Court reiterated that procedural rules are designed to
facilitate justice, not obstruct it, and thus, the RTC's actions were deemed erroneous and
unjustly deprived the petitioner of its right to appeal.
Doctrine:
The doctrine established in this case is that excessive or unnecessary procedural requirements
imposed by lower courts, which deviate from established laws or rules, can lead to grave abuse
of discretion. Moreover, the court must prioritize the attainment of justice by allowing parties to
pursue their appeals without being unduly hindered by technicalities that contradict the spirit
of procedural justice.
Facts:

The case involves the Heirs of Arturo Garcia I, who are the petitioners, and the Municipality of Iba,
Zambales, which is the respondent.

The events leading to this case began when Melecio R. Bueno, a tenant-farmer beneficiary of agricultural
land in Poblacion, Iba, Zambales, filed an ejectment suit against the Municipality of Iba on October 18,
1999. Bueno claimed that the Municipality had constructed a public market on a significant portion of
his land without his consent in 1983, and despite his repeated demands for the Municipality to vacate
the property, they failed to do so. The Municipal Trial Court (MTC) ruled in favor of Bueno after due
proceedings. Subsequently, the Municipality of Iba filed a notice of appeal, which the MTC denied due
course. In response, the Municipality sought a remedy through a petition for certiorari in the Regional
Trial Court (RTC) of Iba, Zambales, which was assigned to Branch 69. The RTC granted the Municipality's
petition for certiorari, leading to the substitution of Bueno by his heirs upon his death. The petitioners
then filed a motion for reconsideration against the RTC's decision, which was denied. Aggrieved by this
outcome, the petitioners appealed to the Court of Appeals (CA) via a petition for review under Rule 42 of
the Rules of Court. However, the CA dismissed their petition on October 28, 2003, for being an improper
mode of appeal, and subsequently denied their motion for reconsideration on February 10, 2004.

Issue:

1. Was the petition for review under Rule 42 the correct remedy for the petitioners in challenging
the RTC's decision?

2. Should the Court exercise its equity jurisdiction to allow the petitioners' appeal despite the
improper mode of appeal?

Ruling:

The Supreme Court affirmed the resolutions of the Court of Appeals, which dismissed the petitioners'
petition for review under Rule 42 and denied their motion for reconsideration.

Ratio:

The Court emphasized the importance of adhering to the procedural rules governing appeals. It clarified
that an appeal under Rule 41, which is an ordinary appeal, is a matter of right and requires strict
compliance with the rules, including the timely filing of a notice of appeal and payment of docket fees. In
contrast, a petition for review under Rule 42 is a discretionary remedy, and the CA has the authority to
determine whether to give due course to such petitions. The petitioners' failure to file the appropriate
notice of appeal within the prescribed period and to comply with the necessary requirements resulted
in the forfeiture of their right to appeal. The Court rejected the petitioners' plea for liberality, stating
that the rules of procedure must be followed to ensure the smooth administration of justice. The Court
noted that any relaxation of the rules could undermine the integrity of the judicial process and that the
petitioners did not provide sufficient justification for their non-compliance. Thus, the CA's dismissal of
the petition for review was upheld, reinforcing the principle that procedural rules are essential for the
orderly conduct of judicial proceedings.

Facts:
The case involves the petitioners, Spouses Adolfo Fernandez, Sr. and Lourdes Fernandez, against
the respondents, Spouses Martines Co and Erlinda Co.
The dispute centers on Lot 978, Cad. 439-D, located in Nalsian, Calasiao, Pangasinan. The
property was originally granted to Emilio Torres, who applied for a free patent that was issued
on June 10, 1996, by President Fidel V. Ramos. This patent was registered with the Register of
Deeds for Pangasinan, leading to the issuance of Katibayan ng Orihinal na Titulo Blg. P-35620 in
Torres' name. On July 16, 1996, petitioner Adolfo Fernandez filed an Affidavit of Adverse Claim
against Torres' title, which was later cancelled when Torres filed an Affidavit of Cancellation,
asserting that Fernandez had failed to pursue his claim and had admitted Torres' ownership in a
prior affidavit dated March 20, 1996.
Subsequently, Torres sold the property to the respondents on June 6, 1997, and a new title (TCT
No. T-236032) was issued in the respondents' names. The respondents took possession of the
property, erecting a fence and later mortgaging it to Solid Bank. However, on September 3,
2001, Adolfo Fernandez disturbed their possession by destroying the fence and commencing
construction on the property. The respondents filed a complaint for quieting of title and
injunction, which was dismissed for lack of jurisdiction. They then filed a complaint for forcible
entry/ejectment before the Municipal Trial Court (MTC) in Calasiao, Pangasinan. The MTC ruled
in favor of the respondents, ordering the petitioners to vacate the property and awarding
damages. The petitioners appealed to the Regional Trial Court (RTC), which reversed the
MTC's decision, leading the respondents to appeal to the Court of Appeals. The Court of
Appeals reinstated the MTC's decision but deleted the award for moral and exemplary
damages, prompting the petitioners to file a petition for review.
Issue:
1. Did the Court of Appeals err in ruling that it was unnecessary to inquire into the validity
of the respondents' title despite their claim of possession being anchored on ownership?
2. Did the Court of Appeals err in deciding the case based on the Affidavit of Adolfo
Fernandez, which involved a question of ownership?
3. Did the Court of Appeals err in failing to recognize the petitioners' claim of juridical and
material possession?
4. Did the Court of Appeals err in not ruling on the procedural missteps committed by the
respondents?
 5. Did the Court of Appeals err in hastily deciding the case without informing the
petitioners that it had been submitted for decision?
6. Did the Court of Appeals err in basing its decision on a document that should not have
been admitted as evidence?
Ruling:
The Supreme Court upheld the Decision of the Court of Appeals, affirming that the respondents
are entitled to the possession of Lot 978, Cad. 439-D. The Court ruled that the issues raised by
the petitioners were without merit and that the respondents had established their right to
possess the property.
Ratio:
The Supreme Court reasoned that in cases of unlawful detainer and forcible entry, the primary
issue is who has the better right to possess the property, independent of ownership claims.
However, when ownership is intertwined with possession, the court may address ownership to
determine possession rights. The evidence showed that the respondents and their predecessor
had continuous and actual possession of the property, supported by the free patent issued to
Emilio Torres. The Court emphasized that the adverse claim filed by Fernandez was effectively
nullified by his own admission in the affidavit, where he recognized Torres as the true owner.
The Court also noted that the petitioners' claims of prior possession were based on a
misunderstanding of the property boundaries, as Lot 978 was distinct from Lot 661, which the
petitioners owned. The Court reiterated that the validity of the respondents' title could only be
challenged in a direct action, not in an ejectment case, which is designed to protect actual
possession. The Court concluded that the procedural issues raised by the petitioners did not
merit a reversal of the appellate court's decision, as they were afforded due process and the
rules of procedure should not hinder the pursuit of substantive justice.
END
The Supreme Court ruled that under Rule 42 of the Rules of Court, the Court of Appeals has the
discretion to resolve a case based on the submitted pleadings without necessarily requiring oral
arguments or informing the parties that the case has been submitted for decision. The court
emphasized that the case is deemed submitted for decision upon the filing of the last pleading
or memorandum required by the court. This discretion allows the appellate court to expedite
the resolution of cases while ensuring that parties have the opportunity to present their
arguments.
Facts:

The case involves Narra Nickel Mining and Development Corporation, Tesoro Mining and Development,
Inc., and McArthur Mining, Inc. (collectively referred to as "petitioners") as the petitioners, and Redmont
Consolidated Mines Corporation ("respondent") as the respondent. The events leading to this case
began on November 8, 2006, when Redmont filed an Application for an Exploration Permit (EP) for
mining areas in the Municipalities of Rizal, Bataraza, and Narra, Palawan. However, Redmont discovered
that these areas were already covered by existing Mineral Production Sharing Agreements (MPSA) and
an EP, which had been applied for by the petitioners' predecessors-in-interest with the Mines and
Geosciences Bureau (MGB) of the Department of Environment and Natural Resources (DENR).

Petitioner Narra Nickel had converted its MPSA into a Financial or Technical Assistance Agreement (FTAA)
application prior to Redmont's EP application. Similarly, Tesoro and McArthur also sought to convert
their MPSAs into FTAAs, but their applications were filed after Redmont's EP application. The DENR
Secretary approved the petitioners' FTAA applications on April 5, 2010, leading to the execution of FTAA
No. 05-2010-IVB on April 12, 2010, between the Republic of the Philippines and the petitioners.

Prior to the FTAA's execution, Redmont filed petitions for the denial of the petitioners' MPSA and EP
applications, arguing that the petitioners were disqualified from being grantees due to their common
majority stockholder being a foreign corporation. This issue eventually reached the Supreme Court,
which ruled that the petitioners were foreign corporations under the "Grandfather Rule." Following this,
Redmont filed a petition for the cancellation and/or revocation of the FTAA, asserting that the FTAA was
irregular and that the petitioners had a history of violating laws. The Office of the President (OP) granted
Redmont's petition, leading to the cancellation of the FTAA. The petitioners appealed to the Court of
Appeals (CA), which affirmed the OP's ruling. The petitioners then filed a petition for review on
certiorari before the Supreme Court.

Issue:

The main issue for resolution is whether the Court of Appeals correctly affirmed the Office of the
President's cancellation and/or revocation of the Financial or Technical Assistance Agreement (FTAA).

Ruling:
The Supreme Court granted the petition, declaring the Decision dated February 23, 2012, and the
Resolution dated July 27, 2012, of the Court of Appeals null and void due to lack of jurisdiction.

Ratio:

The Supreme Court held that the Court of Appeals improperly took cognizance of the case under Rule 43
of the Rules of Court because the OP's cancellation of the FTAA was not an exercise of quasi-judicial
authority. The OP's action was deemed administrative, as it involved the exercise of a contractual right
under the FTAA, which is a government contract. The Court emphasized that the OP, as a contracting
party, could not adjudicate the validity of the contract it was a party to, as this would violate the
principle of mutuality of contracts. The Court further clarified that the OP's cancellation of the FTAA was
not a judicial or quasi-judicial act, and thus, the CA had no jurisdiction to review the OP's decision. The
ruling underscored the importance of adhering to proper procedures in administrative actions and the
distinction between administrative and quasi-judicial functions.
Facts:

The case involves Prisco Lanzaderas, Samuel Sadicon, Angelo Mabanta, Vicente Giberson, Longino
Nambatac, Eleno Aceron, and Salvador Virtudazo (hereinafter referred to as "petitioners") as the
complainants against Amethyst Security and General Services, Inc. (formerly Calmar Security Agency),
Resin Industrial Chemical Corp. (RICC), and Philippine Iron Construction and Marine Works, Inc. (PICMW)
(hereinafter referred to as "respondents").

The events leading to this case began when the petitioners, who were employed as security guards,
were relieved from their posts due to a stipulated age limit in the service contracts between
RICC/PICMW and Amethyst Security. The petitioners were over 45 years old and received a
memorandum on January 30, 1998, relieving them from their positions effective February 1, 1998. They
were instructed to report to Amethyst's main office for reassignment, with a warning that failure to
comply would be considered as absence without official leave (AWOL).

On April 21, 1998, Amethyst issued a Detail Order for the petitioners to report for new assignments as
firewatch guards, which they were warned would also be considered AWOL if they did not comply. The
petitioners subsequently filed complaints for illegal dismissal on March 23 and April 2, 1998. The Labor
Arbiter ruled in favor of the petitioners on November 27, 1998, declaring their dismissal illegal and
ordering the respondents to pay them a total of P1,251,664.41 in monetary benefits. However, the
respondents appealed to the National Labor Relations Commission (NLRC), which reversed the Labor
Arbiter's decision on March 19, 1999, stating that the relief of the petitioners was a legitimate exercise of
business prerogative. The NLRC limited the monetary award to salary differentials for a specific period.
The petitioners' motion for reconsideration was denied, leading them to file a petition with the Court
of Appeals under Rule 43 of the 1997 Rules of Civil Procedure. The Court of Appeals dismissed the
petition for procedural errors, prompting the petitioners to elevate the matter to the Supreme Court.

Issue:

1. Did the Court of Appeals err in dismissing the petition filed under Rule 43 of the Rules of Court
for being the wrong mode of appeal?

2. Were the petitioners constructively dismissed, thus entitling them to their claims and other
monetary benefits?

Ruling:

The Supreme Court ruled that the petitioners' appeal was properly denied due to the procedural lapse
of filing under the wrong mode of appeal. The Court affirmed the Court of Appeals' dismissal of the
petition and found that the petitioners were not constructively dismissed.

Ratio:

The Supreme Court emphasized that the petitioners' choice to file under Rule 43 was incorrect, as
appeals from the NLRC should be made through a special civil action for certiorari under Rule 65 of the
1997 Rules of Civil Procedure. The Court noted that procedural rules are essential for the effective
administration of justice and should not be disregarded lightly. The petitioners failed to allege "grave
abuse of discretion" in their appeal, which is a necessary requirement for certiorari.

On the issue of constructive dismissal, the Court found that the age requirement for security guards was
a valid contractual stipulation that had been consistently applied since 1968. The petitioners could not
claim ignorance of this provision, and their failure to report for reassignment was deemed a defiant
action. The Court ruled that the change in their assignments did not constitute a demotion or a
significant change in their employment conditions, thus failing to meet the criteria for constructive
dismissal. The inherent right of the employer to specify qualifications for personnel assigned to their
premises was upheld, and the petitioners' claims for illegal dismissal were dismissed.
Facts:
The case involves Justina Maniebo, a local government employee who was dismissed from her
position as Cashier III in the Office of the Municipal Treasurer of Puerto Galera, Oriental
Mindoro.
The dismissal stemmed from her dishonesty in claiming to hold a civil service eligibility that she
did not possess. On July 1, 1994, the Mayor of Puerto Galera appointed her to the position
based on her Personal Data Sheet, which falsely indicated that she had passed the Career
Service (Professional) examination with a rating of 74.01% on July 17, 1983. However, upon
verification, it was revealed that she had actually failed the examination, receiving a score of
only 60%.
The Civil Service Commission (CSC) Regional Office No. IV conducted a preliminary investigation
and found sufficient grounds to charge Maniebo with possession of a spurious report of rating,
falsification, grave misconduct, and dishonesty. On December 16, 1999, the CSCRO No. IV found
her guilty and imposed the penalty of dismissal. Maniebo appealed this decision to the CSC,
which affirmed the dismissal on March 20, 2002. Following a failed motion for
reconsideration, she sought relief from the Court of Appeals (CA), which dismissed her
petition for review on September 5, 2002, due to her failure to attach the required certified
true copies of the relevant documents. Subsequent motions for reconsideration were also
denied, leading to her appeal to the Supreme Court.
Issue:
1. Did the Court of Appeals commit reversible error in dismissing Maniebo's petition for
review for failure to attach certified copies of the annexes when the rules and
jurisprudence do not require that all annexes attached to the petition should be
certified?
2. Did the Court of Appeals err in dismissing the petition based on alleged technicality
which was not sanctioned by jurisprudence?
Ruling:
The Supreme Court ruled against Maniebo, affirming the resolutions of the Court of Appeals
dated September 5, 2002, January 8, 2003, and June 5, 2003. The Court found that the CA did
not commit reversible error in dismissing her petition for review due to her failure to comply
with procedural requirements.
Ratio:
The Supreme Court emphasized the importance of adhering to procedural rules, particularly
those outlined in Section 6, Rule 43 of the Rules of Court, which mandates that a petition for
review must be accompanied by certified true copies of the relevant documents. The Court
noted that the requirement for certified copies is not merely a technicality but serves to ensure
that the appellate court has all necessary information to make an informed decision. The Court
rejected Maniebo's argument for liberal construction of the rules, stating that her failure to
comply with the requirements was significant and warranted dismissal of her appeal.
Furthermore, the Court addressed her claims of good faith regarding her eligibility, stating that
her mere assertion of innocence was insufficient to counter the evidence of her dishonesty. The
Court reiterated that possession of a forged document raises a presumption of guilt, which she
failed to rebut with credible evidence. The Court also clarified that the provisions of Republic
Act No. 6850, which grants civil service eligibility to long-serving employees, do not
retroactively cure the invalidity of her initial appointment based on false representations. The
dismissal was deemed appropriate given the gravity of her offenses, which included dishonesty
and falsification, both of which are grounds for dismissal under civil service rules.
Facts:
The case involves Pagayanan R. Hadji-Sirad (petitioner) and the Civil Service Commission (CSC)
(respondent).
The events leading to the case began on February 4, 2002, when Hadji-Sirad, an employee of
the Commission on Audit (COA) in the Autonomous Region for Muslim Mindanao (ARMM), was
formally charged by the CSC Regional Office No. XII with Dishonesty, Grave Misconduct, and
Conduct Prejudicial to the Best Interest of the Service. The charges stemmed from allegations
that Hadji-Sirad allowed another person to take the Career Service Professional Examination on
her behalf on October 17, 1993. The investigation revealed discrepancies between her Personal
Data Sheet (PDS) and the examination records, particularly in the photographs and signatures.
A formal investigation was conducted, during which Hadji-Sirad requested multiple
postponements of hearings. The hearings eventually took place, and evidence was presented by
both the prosecution and the defense. On February 27, 2006, CSCRO No. XII found Hadji-Sirad
guilty and dismissed her from service, imposing accessory penalties including forfeiture of
retirement benefits and disqualification from future government service. Hadji-Sirad's Motion
for Reconsideration was denied, prompting her to appeal to the CSC, which affirmed the lower
office's decision on May 7, 2007. A subsequent Motion for Reconsideration was also denied on
November 26, 2007.
Dissatisfied, Hadji-Sirad filed a Petition for Certiorari with the Court of Appeals, which was
dismissed on January 18, 2008, for being the wrong mode of appeal and for failing to comply
with procedural requirements. A Motion for Reconsideration was similarly denied on March 12,
2008. Hadji-Sirad then elevated the matter to the Supreme Court, seeking a review of the Court
of Appeals' resolutions.
Issue:
1. Is Rule 65 the proper remedy for Hadji-Sirad's case?
 2. Did the Court of Appeals err in dismissing Hadji-Sirad's Petition for Certiorari based on
mere technicalities?
3. Did the Civil Service Commission commit grave abuse of discretion by ignoring important
evidence presented by Hadji-Sirad?
Ruling:
1. The Supreme Court ruled that Rule 65 was not the proper remedy for Hadji-Sirad's case.
2. The Court of Appeals did not err in dismissing the Petition for Certiorari based on
procedural non-compliance.
3. The Civil Service Commission did not commit grave abuse of discretion; the evidence
against Hadji-Sirad was substantial.
Ratio:
The Supreme Court emphasized that the Court of Appeals correctly dismissed Hadji-Sirad's
Petition for Certiorari because she failed to follow the proper procedure for appealing decisions
of the CSC, which should have been through a petition for review under Rule 43, not a special
civil action for certiorari under Rule 65. The Court reiterated that certiorari is not a substitute for
a lost or lapsed remedy of appeal and that the remedies of appeal and certiorari are mutually
exclusive.
Furthermore, the Court noted that Hadji-Sirad's failure to comply with the procedural
requirements of Rule 65, particularly in indicating material dates and appending necessary
documents, justified the dismissal of her petition. The Court acknowledged that while
procedural rules are designed to promote efficiency and order, they are not intended to
frustrate justice. However, Hadji-Sirad did not provide sufficient justification for her procedural
lapses.
On the merits, the Court found that Hadji-Sirad was afforded due process throughout the
administrative proceedings, having been given notice of the charges, the opportunity to present
evidence, and the chance to seek reconsideration of the decisions against her. The findings of
the CSC were supported by substantial evidence, including discrepancies in photographs and
signatures, which led to the conclusion that Hadji-Sirad had allowed another person to take the
examination on her behalf. The Court upheld the CSC's decision to dismiss Hadji-Sirad from
service, affirming the penalties imposed.
Facts:

The case involves a petition for certiorari filed by the University of Mindanao, Inc. and several
individuals, including Dr. Guillermo P. Torres, Atty. Victor Nicasio P. Torres, and others, against the
Philippine Deposit Insurance Corporation (PDIC).

The events leading to this case began on August 31, 1990, when the Monetary Board issued a resolution
to close the Mindanao Savings and Loan Association (MSLA), placing it under the receivership of the
PDIC. Subsequently, on May 24, 1991, the Board ordered the liquidation of MSLA and designated the
PDIC as the liquidator. The PDIC filed a petition for assistance in the liquidation process before the
Regional Trial Court (RTC) of Davao City, which was granted on September 29, 1991. Over the years, the
RTC issued several orders directing the PDIC to expedite the liquidation process, including a reminder for
a liquidation plan and an inventory of MSLA's assets.

On April 20, 2005, the RTC issued a resolution terminating the liquidation proceedings due to the PDIC's
failure to comply with mandatory requirements, including inventory and publication of claims. The RTC
ordered the PDIC to pay approved claims and deliver remaining MSLA assets to the claimants. The PDIC
appealed this resolution, and the Bangko Sentral ng Pilipinas (BSP) also filed a notice of appeal. The
RTC granted the PDIC an extension to file its record on appeal, which was subsequently approved.
However, the petitioners filed a motion to dismiss the PDIC's appeal, arguing that the PDIC failed to
comply with procedural requirements. The Court of Appeals (CA) denied the motion to dismiss,
leading to the present petition for certiorari.

Issue:

1. Did the Court of Appeals commit grave abuse of discretion in disregarding the petitioners'
motion to dismiss the appeal based on the PDIC's failure to comply with procedural
requirements?

2. Was the PDIC's notice of appeal defective, warranting dismissal of the appeal?

3. Did the Court of Appeals err in finding that the PDIC's record on appeal included the necessary
data showing its timely perfection?

4. Should the Court of Appeals have applied different jurisprudence in dismissing the appeal?
Ruling:

The Supreme Court dismissed the petition, affirming the resolutions of the Court of Appeals dated July 6,
2007, and October 24, 2007. The Court found no merit in the petitioners' arguments regarding the
procedural deficiencies claimed against the PDIC's appeal.

Ratio:

The Supreme Court ruled that the denial of a motion to dismiss is an interlocutory order and cannot be
the subject of a certiorari petition unless it is shown that the court acted without or in excess of
jurisdiction or with grave abuse of discretion. The Court emphasized that mere abuse of discretion is
insufficient; it must be grave and evident. The petitioners argued that the CA disregarded the mandatory
requirements of filing multiple copies of the approved record on appeal. However, the Court clarified
that the rules do not explicitly state that non-submission of copies is a ground for dismissal. The Court
also noted that the PDIC had substantially complied with the requirements for the perfection of its
appeal, as the CA had previously affirmed the RTC's findings regarding the timeliness of the PDIC's filings.

Furthermore, the Court highlighted that the rules of procedure should be liberally construed to promote
justice rather than frustrate it. The petitioners' reliance on previous jurisprudence was deemed
misplaced, as the cases cited involved different circumstances. The Court reiterated that the dismissal of
appeals on purely technical grounds is discouraged, and judicial action should prioritize the merits of the
case over procedural technicalities. Thus, the CA's decision to deny the motion to dismiss was upheld,
and the petition was dismissed.
Facts:

The case involves two petitions filed by Aida P. BaAez (petitioner) against Gabriel B. BaAez (respondent)
concerning a legal separation and the subsequent orders issued by the Regional Trial Court of Cebu,
Branch 20, in Civil Case No. CEB-16765. The trial court's decision, dated September 23, 1996, granted
legal separation between Aida and Gabriel on the grounds of Gabriel's sexual infidelity. The court also
ordered the dissolution of their conjugal property relations, the division of their net conjugal assets, and
the forfeiture of Gabriel's share in favor of their common children. Additionally, the court mandated
Gabriel to surrender a Mazda motor vehicle and a smaller residential house located in Maria Luisa Estate
Park Subdivision to Aida and their children within 15 days of receiving the decision.

Following this, Aida filed an urgent ex-parte motion to modify the decision, while Gabriel filed a Notice
of Appeal. On October 1, 1996, the trial court granted Aida's motion, allowing her to pay attorney's fees
equivalent to 5% of Gabriel's share in the net conjugal assets and ordering the payment of P100,000 as
advance attorney's fees to Aida's counsel. Aida later sought moral and exemplary damages and filed a
motion for execution pending appeal. Gabriel opposed these motions and sought reconsideration of the
October 1 order. On November 22, 1996, the trial court denied Aida's request for damages but granted
the execution pending appeal. Gabriel subsequently elevated the case to the Court of Appeals, which, on
March 21, 1997, set aside the trial court's orders regarding the execution and the advance attorney's
fees. Aida's motion for reconsideration was denied on February 10, 1998, leading to the filing of the first
petition (G.R. No. 132592). Meanwhile, Gabriel's appeal was processed, and Aida filed a motion to
dismiss it, claiming Gabriel failed to file a Record on Appeal. The Court of Appeals denied Aida's motion
on February 10, 1998, prompting the second petition (G.R. No. 133628). The Supreme Court
consolidated both petitions for resolution.

Issue:

1. In G.R. No. 132592, did the Court of Appeals err in setting aside the trial court's grant of
execution pending appeal regarding the order for Gabriel to vacate the residential house and the
payment of P100,000 to Aida's counsel?

2. In G.R. No. 133628, did the Court of Appeals err in denying Aida's motion to dismiss Gabriel's
appeal for failure to file a Record on Appeal?

Ruling:

1. The Supreme Court denied the petition in G.R. No. 132592, affirming the Court of Appeals'
decision to set aside the trial court's orders regarding execution pending appeal and the advance
attorney's fees.
 2. The Supreme Court also denied the petition in G.R. No. 133628, affirming the Court of
Appeals' resolution to deny Aida's motion to dismiss Gabriel's appeal.

Ratio:

In G.R. No. 132592, the Supreme Court held that the execution of a judgment pending appeal is
permissible only when there are superior circumstances demanding urgency that outweigh the potential
damages to the other party. The Court found that Aida failed to demonstrate such urgency, noting that
she had other properties in the United States and did not intend to occupy the residential house in
question. The Court emphasized that merely posting a bond does not justify execution pending appeal,
as it could lead to routine executions rather than being an exception. Regarding the P100,000 advance
attorney's fees, the Court ruled that there was no justification for pre-empting the appellate court's
judgment on this matter while the trial court's decision was still under appeal.

In G.R. No. 133628, the Supreme Court clarified that an action for legal separation does not fall under
the category of cases allowing multiple appeals. The Court referenced previous jurisprudence, stating
that the issues arising from a legal separation are interconnected and do not permit separate appeals.
Consequently, the Court upheld the Court of Appeals' decision to deny Aida's motion to dismiss Gabriel's
appeal for lack of a Record on Appeal, affirming that the appeal process should continue without the
need for a separate record.

END

The Supreme Court referenced Rule 41 in the context of the appeal process, specifically addressing the
requirement of a record on appeal. The Court clarified that Section 39 of B.P. 129 abolished the
requirement of a record on appeal, except in special proceedings and cases where multiple appeals are
allowed. The Court emphasized that an action for legal separation does not fall under the category of
cases permitting multiple appeals, thus supporting its decision to deny Aida's motion to dismiss Gabriel's
appeal for failure to file a record on appeal.
Facts:

The case involves Philippine Rabbit Bus Lines, Inc. (petitioner) and respondents Nelson Goimco, Sr., and
spouses Isabelo and Remegia Ladia.

The incident that led to the legal dispute occurred on October 17, 1983, when the petitioner’s bus No.
309 collided with a ten-wheeler truck in Dolores, Mabalacat, Pampanga, resulting in injuries to several
passengers. Nelson Goimco, Sr., one of the injured passengers, filed a complaint for breach of contract of
carriage against the petitioner with the Regional Trial Court (RTC) of Tarlac City, which was docketed as
Civil Case No. 6977. The spouses Isabelo and Remegia Ladia, whose son Isabelo Ladia, Jr. died in the
accident, also filed a similar complaint, docketed as Civil Case No. 7054. The two cases were
consolidated for joint hearing.

After the trial, the RTC rendered a Joint Decision in favor of the plaintiffs, ordering the petitioner to pay
Goimco P248,157.38 in actual damages, P100,000.00 in moral damages, P100,000.00 in exemplary
damages, and P50,000.00 in attorney's fees. The court also ordered the petitioner to pay the heirs of
Isabelo Ladia, Jr. P50,000.00 for his death, P75,000.00 in actual damages, and P15,000.00 in attorney's
fees.

Following the decision, both parties filed motions for reconsideration. The RTC denied the petitioner’s
motion but granted the respondents’ motions, amending the decision to award Goimco P679,629.60 for
loss of income and P100,980.00 to the heirs of Isabelo Ladia, Jr. for the same reason.

The petitioner appealed to the Court of Appeals but failed to file the required appellant's brief within
the reglementary period. The Court of Appeals dismissed the appeal on February 3, 1998, citing the
failure to comply with procedural requirements. The petitioner filed a motion for reconsideration,
claiming that the failure was due to the loss of its counsel's office logbook, which contained important
deadlines. The Court of Appeals denied this motion, stating that the counsel could have managed the
deadlines with ordinary prudence. Consequently, the petitioner filed a petition for certiorari, which is the
subject of this case.

Issue:

1. Did the Court of Appeals err in dismissing the appeal of Philippine Rabbit Bus Lines, Inc. for
failure to file the appellant's brief within the reglementary period?

2. Was the petitioner denied due process due to the dismissal of its appeal?

Ruling:

1. The Supreme Court ruled that the Court of Appeals did not err in dismissing the appeal of
Philippine Rabbit Bus Lines, Inc. for failure to file the required appellant's brief.
 2. The Supreme Court held that there was no denial of due process in the dismissal of the appeal.

Ratio:

The Supreme Court emphasized that the right to appeal is not an inherent right but a statutory remedy
that must be exercised in accordance with the law. The Court of Appeals acted within its jurisdiction
when it dismissed the appeal due to the petitioner's failure to file the appellant's brief as mandated by
the rules. The Court reiterated that the procedural requirements for filing an appeal must be strictly
adhered to, as they are designed to ensure the orderly and prompt disposition of cases. The petitioner’s
claim that its counsel's logbook was lost was deemed unpersuasive, as the counsel had a duty to manage
the case effectively and could have checked the records to ensure compliance with deadlines. The Court
also noted that the negligence of counsel is binding on the client, and thus, the petitioner could not
escape the consequences of its counsel's inaction. Furthermore, the Court clarified that there is no
denial of due process when the adverse ruling is attributable to the negligence of the party's counsel.
Therefore, the petition for certiorari was dismissed, and costs were ordered against the petitioner.
Facts:

The case involves Jorge L. Tiangco and the heirs of Enrique L. Tiangco, namely Gloria T. Batungbacal,
Narciso L. Tiangco, and Silvino L. Tiangco, as petitioners against the Land Bank of the Philippines (LBP) as
the respondent.

The events leading to this case began on August 11, 1994, when the petitioners filed a complaint with
the Regional Trial Court (RTC) of Bataan. The complaint sought the "Fixing and Payment of Land
Compensation and Annulment of Titles & Emancipation Patents" against the Secretary of Agrarian
Reform, the Register of Deeds of Bataan, and several private individuals identified as their tenants. The
petitioners claimed ownership of a parcel of land in Cupang, Balanga, Bataan, covering an area of
141,716 square meters, which was unlawfully distributed to the tenants without their consent and
without compensation. The complaint was later amended to include the LBP as an additional defendant.

In their defense, the Secretary of Agrarian Reform argued that the petitioners failed to exhaust
administrative remedies, as the case should have been brought before the DAR Adjudication Board. The
private tenants contended that they were lawfully issued Emancipation Patents and that the petitioners
had already been compensated through the LBP financing scheme. The LBP also denied the allegations,
asserting that it was not responsible for the valuation of the land, which was under the jurisdiction of
the DAR.

On June 9, 1998, the RTC ruled in favor of the petitioners, appraising the land at P30.00 per square
meter. Following this, the LBP and the DAR filed appeals with the Court of Appeals (CA). The CA
dismissed the appeal of the tenants for failure to pay the required fees but allowed the appeals of the
LBP and DAR to proceed. The petitioners filed a motion to dismiss the LBP's appeal, arguing that it was
improperly filed and that the LBP failed to serve the required number of copies of its brief. The CA
denied the motion to dismiss on October 5, 2001, and subsequently denied the petitioners' motion for
reconsideration on June 4, 2002. The petitioners then filed a special civil action for certiorari to challenge
these resolutions.

Issue:

1. Did the Court of Appeals err in denying the petitioners' motion to dismiss the appeal of the
LBP on the grounds that the appeal had become final and executory?

2. Did the LBP fail to serve the required two copies of its Appellant's Brief to the petitioners?

3. Should the LBP be deemed to have not filed a brief due to its failure to file within the
reglementary period?

Ruling:
The Supreme Court dismissed the petition for lack of merit, affirming the resolutions of the Court of
Appeals dated October 5, 2001, and June 4, 2002. The Court ruled that the LBP's appeal could be acted
upon despite the procedural issues raised by the petitioners.

Ratio:

The Supreme Court held that the LBP's appeal was valid despite the petitioners' claims regarding the
finality of the RTC's decision. The Court clarified that the ruling in the case of Land Bank of the
Philippines v. De Leon, which established that a petition for review is the correct mode of appeal from
decisions of Special Agrarian Courts, would apply prospectively. Since the LBP filed its notice of appeal
before the finality of the De Leon ruling, its appeal could still be considered.

Regarding the failure to serve two copies of the Appellant's Brief, the Court noted that while the Rules of
Court require such service, the failure to do so does not automatically result in the dismissal of the
appeal. The CA has discretion in this matter, and the petitioners did not demonstrate that they suffered
material injury due to the procedural lapse. The Court emphasized that the rules of procedure should
not be applied rigidly to the detriment of substantial justice, and the LBP's delay in filing its brief was
justified by circumstances beyond its control, including a reorganization within its legal department. The
Court concluded that the CA did not commit grave abuse of discretion in denying the petitioners' motion
to dismiss the LBP's appeal.
Facts:
The case involves Atty. Anacleto B. Buena, Jr., in his capacity as the Regional Director of the Civil
Service Commission (CSC) for the Autonomous Region in Muslim Mindanao (ARMM), as the
petitioner, and Dr. Sangcad D. Benito as the respondent.
The events leading to the case began on August 27, 2004, when Dr. Parouk S. Hussin, the
Regional Governor of ARMM, appointed Dr. Benito as the Assistant Schools Division
Superintendent of the Department of Education, Division of Lanao del Sur-I, in a temporary
capacity. On June 20, 2005, Dr. Hussin reappointed Dr. Benito in a permanent capacity and
requested the CSC Regional Office to attest to this appointment. However, the Regional Office,
led by Regional Director Buena, returned the appointment, stating that Dr. Benito lacked the
required career executive service eligibility for the position.
In response, Dr. Benito filed a petition for mandamus with the Regional Trial Court (RTC) of
Lanao del Sur on August 24, 2005, arguing that the position did not require such eligibility
according to the Administrative Code of 1987. The RTC ruled in favor of Dr. Benito on September
12, 2005, ordering the CSC Regional Office to attest to his appointment. Following this, the
Regional Office filed a motion for reconsideration, which was denied, and subsequently, an
appeal was made to the Court of Appeals. The appeal was dismissed due to the Regional
Office's failure to file a required memorandum, leading to further legal proceedings, including
a petition for review on certiorari to the Supreme Court.
Issue:
1. Did the Court of Appeals err in dismissing the Civil Service Commission Regional
Office's appeal for failure to file the required memorandum?
2. Did Dr. Benito correctly avail himself of a petition for mandamus against the Civil Service
Commission's refusal to attest to his appointment?
3. Does the position of Assistant Schools Division Superintendent require career executive
service eligibility?
Ruling:
 1. The Court of Appeals did not err in dismissing the Civil Service Commission Regional
Office's appeal for failure to file the required memorandum.
2. Dr. Benito correctly availed himself of a petition for mandamus against the Civil Service
Commission's refusal to attest to his appointment.
3. The position of Assistant Schools Division Superintendent is a position in the Career
Executive Service, and thus requires career executive service eligibility.
Ratio:
The Supreme Court upheld the Court of Appeals' dismissal of the appeal due to the Regional
Office's failure to comply with procedural requirements, specifically the non-filing of a
memorandum, which is a ground for dismissal under the Rules of Civil Procedure. The Court
emphasized that heavy workload or administrative oversight does not excuse non-compliance
with court orders.
Regarding the petition for mandamus, the Court ruled that it was the proper remedy for Dr.
Benito, as the Civil Service Commission has a ministerial duty to attest to appointments once
eligibility is established. The Court clarified that the question of whether the position
required career executive service eligibility was a purely legal issue, thus falling within
exceptions to the exhaustion of administrative remedies.
On the merits, the Court determined that the position of Assistant Schools Division
Superintendent indeed falls under the Career Executive Service, as it meets the criteria set forth
by the Career Executive Service Board, including being a career position, being above the
division chief level, and involving executive and managerial functions. The Court noted that the
position requires the appointee to possess career executive service eligibility, which Dr. Benito
did not have at the time of his appointment. Consequently, the Civil Service Commission could
not be compelled to attest to his permanent appointment.
Facts:
The case involves Rosemarie B. Bintudan, who served as the Disbursing Officer II at the
Department of Interior and Local Government-Cordillera Administrative Region (DILG-CAR)
Provincial Office located in Lagawe, Ifugao.
On March 16, 2005, unidentified suspects broke into the DILG-CAR Provincial Office, forcibly
destroying windows and steel grills, and stole cash amounting to P114,907.30 from the safety
vault. Following the incident, Bintudan reported the robbery to the Provincial Office and the
Audit Team Leader (ATL) on March 17, 2005. On April 6, 2005, she requested to be relieved from
liability for the stolen funds. The Lagawe Police confirmed the robbery in a report dated May 5,
2005, stating that efforts to identify the suspects were unsuccessful. The ATL's investigation
revealed that the vault was opened easily by the robbers using a number combination that had
been posted on the vault's door. The ATL's report also noted that the funds taken represented
salaries and wages for DILG personnel, and questioned the early withdrawal of salaries just days
before the robbery. The COA's Legal and Adjudication Office (LAO-N) denied Bintudan's request
for relief from accountability due to her negligence. Despite her claims that she did not post the
combination and that the practice had been established prior to her tenure, the COA found her
actions contributed to the loss. Bintudan's subsequent appeals to the COA Commission Proper
were denied, leading her to file a petition for review on certiorari, arguing that the COA erred
in finding her guilty of negligence.
Issue:
1. Did the Commission on Audit err in finding Rosemarie B. Bintudan guilty of negligence,
thereby denying her request for relief from accountability for the loss of funds?
Ruling:
The Supreme Court denied the petition for review, affirming the decision of the Commission on
Audit.
Ratio:
The Court ruled that the petitioner's remedy was improperly filed as a petition for review on
certiorari under Rule 45, which is applicable only to decisions from lower courts, not quasi-
judicial bodies like the COA. The proper recourse should have been a petition for certiorari
under Rule 64. The Court emphasized that the COA is constitutionally mandated to oversee
public funds and has broad powers to audit government accounts. The findings of negligence
against Bintudan were supported by substantial evidence, including her failure to secure the
vault properly and her negligence in leaving the combination posted on the vault's door. The
Court defined negligence as the omission to do something that a reasonable person would do,
and in this case, Bintudan's actions fell short of the standard of care required for safeguarding
public funds. The Court concluded that her negligence directly contributed to the loss of funds,
and thus, she could not be relieved of her accountability. The decision underscored the
importance of diligence and prudence in the handling of public funds, affirming that
accountability cannot be evaded by merely claiming a lack of personal involvement in negligent
practices.
Facts:

END

The Supreme Court ruled that only questions of law can be raised in a petition for review on
certiorari under Rule 45 of the Rules of Court. It emphasized that if the issue requires reviewing
or evaluating the evidence on record, it is considered a question of fact, which is generally not
within the Court's jurisdiction to resolve. In this case, the petitioner raised issues that had
already been factually determined by the lower courts, and thus, the Supreme Court found it
could not entertain the appeal as it involved questions of fact rather than law.
Facts:
The case involves Atty. Jesus F. Fernandez as the petitioner and Concepcion Olivares as the
respondent.
The dispute originated from a complaint for unlawful detainer filed by Olivares against
Fernandez on January 23, 1993, which was docketed as Civil Case No. 140953 in the
Metropolitan Trial Court (MeTC) of Manila, Branch XV. The MeTC dismissed the complaint due
to a lack of sufficient cause of action. Olivares subsequently appealed the dismissal to the
Regional Trial Court (RTC) of Manila, Branch 46, which reversed the MeTC's decision on May 2,
1994, ordering Fernandez to pay rental arrears, attorney's fees, litigation expenses, and costs.
Fernandez received a copy of this decision on June 28, 1994, and filed a Motion for
Reconsideration on July 12, 1994, which was denied on November 29, 1994. On December 1,
1994, Fernandez filed a Motion for Extension of Time to File a Petition for Review with the
Court of Appeals, which was granted. However, on December 9, 1994, he filed a Motion for
New Trial before the RTC, citing newly discovered evidence of receipts for rental payments. The
RTC denied the Motion for New Trial on February 6, 1995, asserting that the Court of Appeals
had already acquired jurisdiction over the case when Fernandez filed the Motion for Extension
of Time. Fernandez's subsequent motions for reconsideration were denied, and Olivares moved
for the execution of the RTC's judgment. The RTC granted the motion for execution on January
30, 1996, leading Fernandez to file a Petition for Certiorari, Prohibition, and Mandamus with the
Court of Appeals. The Court of Appeals temporarily restrained the execution of the writ pending
resolution of the petition but ultimately denied Fernandez's petition on May 16, 1997, affirming
the RTC's decision.
Issue:
The main issue raised in this case is: Whether the mere filing by the petitioner of a Motion for
Extension of Time to File a Petition for Review automatically divested the Regional Trial Court
(RTC) of its jurisdiction to entertain a Motion for New Trial.
Ruling:
The Supreme Court ruled that the petition was denied for lack of merit, affirming the RTC's
decision and ordering the execution of the RTC's judgment dated May 2, 1994.
Ratio:
The Court's reasoning centered on the jurisdictional principles governing the appellate process.
It established that jurisdiction over a case is conferred by law and is acquired through the
proper filing of motions and petitions. The Court noted that while the filing of a motion for
extension of time to file a petition for review is considered a voluntary submission to the
jurisdiction of the appellate court, it does not automatically divest the RTC of its jurisdiction
over the case. The Court emphasized that the RTC retains residual jurisdiction to rule on
matters not involved in the appeal, such as motions for new trial, until the appeal is perfected.
In this case, the Court found that Fernandez's motion for new trial was filed out of time, as he
had only one day left to file it after his motion for reconsideration was denied. The Court
reiterated that the period for filing a motion for new trial is non-extendable and must be filed
within the original period for appeal. Since Fernandez failed to file the motion for new trial
within the prescribed period, he effectively forfeited his right to seek relief from the RTC. The
Court concluded that the RTC had not lost its jurisdiction when Fernandez filed his motion for
new trial, but since the motion was untimely, the RTC's decision remained executory.
Facts:
The case involves a petition for review on certiorari filed by Jose Vicente Atilano II and the heirs
of Carlos V. Tan, represented by Conrad K. Tan, Carlos K. Tan, Camilo Karl K. Tan, Carisa Rosenda
T. Go, Nelida F. Atilano, and Isidra K. Tan (hereinafter referred to as "petitioners") against Hon.
Judge Tibing A. Asaali, the presiding judge of the Regional Trial Court (RTC) of Zamboanga City,
and Atlantic Merchandising, Inc. (hereinafter referred to as "respondent").
The events leading to this case began in January 1990 when Atlantic Merchandising, Inc. filed an
action for revival of judgment against Zamboanga Alta Consolidated, Inc. (ZACI) in the RTC of
Zamboanga City, which was docketed as Civil Case No. 3776. On January 31, 1991, the RTC
issued a decision reviving a previous judgment in Civil Case No. 3049, ordering ZACI to pay the
respondent P673,536.54, which included principal obligations, interest, attorney's fees, and
costs. A writ of execution was issued, but it was returned unsatisfied, prompting the respondent
to seek the examination of ZACI's debtors, including the petitioners, who were stockholders of
ZACI. The petitioners denied any liability for unpaid subscriptions and presented evidence from
the Securities and Exchange Commission (SEC) to support their claims. However, the RTC found
the petitioners liable for unpaid stock subscriptions amounting to P750,000.00 and ordered
them to settle this obligation in its September 29, 2004 decision. The petitioners' motion for
reconsideration was denied on December 9, 2004. Subsequently, the petitioners filed a petition
for certiorari with the Court of Appeals (CA), which was dismissed on May 27, 2005, due to
procedural deficiencies. The petitioners attempted to rectify these issues but were ultimately
denied reconsideration on September 6, 2006, as the CA found that the payment of the docket
fee was made beyond the reglementary period.
Issue:
1. Did the Court of Appeals err in dismissing the petition for certiorari on procedural
grounds despite the petitioners' substantial compliance with the requirements?
2. Did the RTC violate the petitioners' right to due process by ordering them to pay the
alleged unpaid stock subscriptions without a proper trial on the merits?
Ruling:
The Supreme Court granted the petition, set aside the CA's resolutions dated May 27, 2005, and
September 6, 2006, and nullified the RTC's September 29, 2004 decision and December 9, 2004
order. The Court ruled that the petitioners should not be held liable without a proper trial and
that the respondent should institute a separate action against the petitioners to recover any
alleged indebtedness.
Ratio:
The Supreme Court emphasized that while the payment of docket fees is essential for the
perfection of an appeal, procedural rules may be relaxed in the interest of substantial justice,
especially when strict adherence could lead to an injustice. The Court noted that the petitioners
were not parties to the original case between ZACI and the respondent and had denied any
liability for the alleged unpaid stock subscriptions. The Court reiterated that due process
requires that a party must have the opportunity to contest any claims against them in a proper
judicial proceeding. The RTC's decision to hold the petitioners liable without a trial on the merits
constituted a violation of their right to due process, as they were total strangers to the original
case. The Court concluded that the RTC should have directed the respondent to file a separate
action against the petitioners, as provided under Section 43, Rule 39 of the Rules of Court,
which governs the proceedings when a third party denies indebtedness. The ruling underscored
the principle that no individual should be adversely affected by a judgment in which they were
not a party, thereby reinforcing the importance of due process in judicial proceedings.
Facts:
The case involves Metropolitan Bank & Trust Company (Metrobank) as the petitioner and
Absolute Management Corporation (AMC) as the respondent.
The events leading to the case began on October 5, 2000, when Sherwood Holdings
Corporation, Inc. (SHCI) filed a complaint for a sum of money against AMC, which was assigned
to the Regional Trial Court (RTC) of Quezon City, Branch 80, under Civil Case No. Q-00-42105.
SHCI alleged that it made advance payments to AMC for the purchase of plywood and plyboards
amounting to P12,277,500.00, covered by several Metrobank checks made payable to AMC.
These checks were given to Jose L. Chua, AMC's General Manager, in 1998. Chua passed away in
1999, and a special proceeding for the settlement of his estate was initiated in the RTC of Pasay
City, which was ongoing at the time AMC filed its answer with counterclaims and a third-party
complaint against Metrobank.
AMC claimed it had no knowledge of the transactions with SHCI and requested the RTC to hold
Metrobank liable for the checks in case it was found liable to SHCI. Metrobank filed a motion for
a bill of particulars to clarify AMC's ambiguous statements, which AMC failed to comply with.
Metrobank also filed a motion to dismiss AMC's claims, arguing that AMC was engaging in
prohibited forum shopping since the claims were the same as those raised against Chua's estate
in the pending special proceedings. The RTC denied Metrobank's motion to dismiss and
deferred consideration of Metrobank's motion to strike out AMC's third-party complaint.
Metrobank later filed a motion for leave to admit a fourth-party complaint against Chua's
estate, asserting that the estate should reimburse Metrobank if it was held liable to AMC. The
RTC denied this motion, categorizing Metrobank's claim as a money claim that should have
been filed in the ongoing judicial settlement of Chua's estate under Section 5, Rule 86 of the
Rules of Court. Metrobank's subsequent petition for certiorari before the Court of Appeals (CA)
was also denied, leading to the present petition for review on certiorari before the Supreme
Court.
Issue:
1. Does the petition for review on certiorari filed by Metrobank comply with the Rules of
Court?
 2. Should Metrobank's fourth-party complaint against Chua's estate be allowed?
Ruling:
1. The Supreme Court ruled that Metrobank's petition for review on certiorari complies
with the Rules of Court.
2. The Court affirmed the CA's decision that Metrobank's fourth-party complaint against
Chua's estate should not be allowed, as it constituted a money claim that must be filed
under Section 5, Rule 86 of the Rules of Court.
Ratio:
The Supreme Court found that Metrobank's failure to append all relevant pleadings from
AMC did not warrant the outright dismissal of its petition, as the essential arguments and
facts were still presented adequately. The Court emphasized that procedural rules should be
liberally construed to promote justice and efficiency in legal proceedings.
On the substantive issue, the Court agreed with the lower courts that Metrobank's claim against
Chua's estate was based on a quasi-contract, specifically under the principle of "solutio
indebiti," which applies when something is delivered by mistake to a person who has no right to
demand it. The Court noted that claims arising from quasi-contracts must be filed in the
settlement of the deceased's estate, as stipulated in Section 5, Rule 86 of the Rules of Court.
The Court also highlighted the principle of lex specialis derogat generali, asserting that the
specific provisions governing claims against deceased persons should prevail over general
provisions applicable to ordinary civil actions. Thus, Metrobank's claim, being contingent on the
outcome of its liability to AMC, fell within the category of claims that should have been filed in
the special proceedings for Chua's estate.
END
The Supreme Court ruled that Metrobank's petition complied with Section 4, Rule 45 of the
Rules of Court. It emphasized that the requirement for petitions is not absolute and that
procedural rules should be liberally construed to promote justice and efficiency. The Court
found that Metrobank's omission to include all relevant pleadings was not fatal to the petition,
as it still provided a clear narration of facts and arguments. Thus, the petition was not dismissed
outright despite the claimed deficiencies.