The plaintiffs filed a complaint for forcible entry against the defendants in municipal court. The municipal court dismissed the complaint, and the plaintiffs appealed to the regional trial court. The regional trial court overturned the municipal court's decision and ordered the defendants to vacate the property. The defendants then appealed to the Court of Appeals. The Court of Appeals dismissed the petition because it did not contain a statement of factual background. However, the Supreme Court found that the petition was in substantial compliance with the rules because the factual background could be found within the petition and annexes. The Supreme Court reversed the Court of Appeals' dismissal and reinstated the municipal court's original decision dismissing the plaintiffs' complaint.
The plaintiffs filed a complaint for forcible entry against the defendants in municipal court. The municipal court dismissed the complaint, and the plaintiffs appealed to the regional trial court. The regional trial court overturned the municipal court's decision and ordered the defendants to vacate the property. The defendants then appealed to the Court of Appeals. The Court of Appeals dismissed the petition because it did not contain a statement of factual background. However, the Supreme Court found that the petition was in substantial compliance with the rules because the factual background could be found within the petition and annexes. The Supreme Court reversed the Court of Appeals' dismissal and reinstated the municipal court's original decision dismissing the plaintiffs' complaint.
The plaintiffs filed a complaint for forcible entry against the defendants in municipal court. The municipal court dismissed the complaint, and the plaintiffs appealed to the regional trial court. The regional trial court overturned the municipal court's decision and ordered the defendants to vacate the property. The defendants then appealed to the Court of Appeals. The Court of Appeals dismissed the petition because it did not contain a statement of factual background. However, the Supreme Court found that the petition was in substantial compliance with the rules because the factual background could be found within the petition and annexes. The Supreme Court reversed the Court of Appeals' dismissal and reinstated the municipal court's original decision dismissing the plaintiffs' complaint.
The plaintiffs filed a complaint for forcible entry against the defendants in municipal court. The municipal court dismissed the complaint, and the plaintiffs appealed to the regional trial court. The regional trial court overturned the municipal court's decision and ordered the defendants to vacate the property. The defendants then appealed to the Court of Appeals. The Court of Appeals dismissed the petition because it did not contain a statement of factual background. However, the Supreme Court found that the petition was in substantial compliance with the rules because the factual background could be found within the petition and annexes. The Supreme Court reversed the Court of Appeals' dismissal and reinstated the municipal court's original decision dismissing the plaintiffs' complaint.
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G.R. No.
188360, January 21, 2010
SP S. HEBER & CHARLITA EDILLO, Petitioners,
versus SPS. NORBERTO & DESIDERIA DULPINA,
BRION, J.:
FACTS:
On February 21, 2006, plaintiffs-respondents Spouses Norberto and
Desideria Dulpina (plaintiffs-respondents) filed a Complaint for Forcible Entry against the defendants-petitioners with the Municipal Circuit Trial Court of Del Carmen-San Isidro-San Benito, Surigao del Norte (MCTC). On May 23, 2007, the MCTC rendered judgment dismissing the Complaint. On June 5, 2007, the plaintiffs-respondents filed a Motion for Reconsideration which the MCTC denied in its Resolution of June 8, 2007. On July 30, 2007, the plaintiffs-respondents filed a Notice of Appeal with the MCTC, which the latter granted. On August 15, 2007, the plaintiffs-respondents filed their Appeal Memorandum with the Regional Trial Court. The RTC decided the appeal on November 7, 2007. It set aside the MCTC judgment and ordered the defendants-petitioners to vacate the subject property and to restore the plaintiffs-respondents to their possession. After the RTC denied their Motion for Reconsideration, the defendants-petitioners elevated the case to the CA through a Petition for Review under Rule 42 of the Rules of Court. They argued that the plaintiffs-respondents’ appeal with the RTC was filed out of time since the Revised Rules of Summary Procedure (RRSP) prohibits the filing of a motion for reconsideration.
The CA dismissed the Petition in its Resolution of January 28, 2009
on the ground that it does not contain a statement of the factual background of the case, in violation of Sections 2 and 3 of Rule 42 of the Rules of Court.
ISSUE OF THE CASE:
Whether or not CA’s outright dismissal of the petition was
unwarranted.
RULING:
We find for the defendants-petitioners. That there was substantial
compliance with the Rules because the background facts can be found within the four corners of the petition and its incorporated annexes, is not a novel ruling for this Court. In the case of Deloso v. Marapao (involving the same deficiency for lack of a specific and separate statement of facts outlining the factual background relied upon), we said: “An examination of the petition filed with the Court of Appeals reveals that while it does not contain a separate section on statement of facts, the facts of the case are, in fact, integrated in the petition particularly in the discussion/argument portion. Moreover, the decision of the DARAB which contains the facts of the case was attached to the petition and was even quoted by the appellate court. The petition also sufficiently discusses the errors committed by the DARAB in its assailed decision.” There was, therefore, substantial compliance with Sec. 6, Rule 43 of the Rules of Court. It is settled that liberal construction of the Rules may be invoked in situations where there may be some excusable formal deficiency or error in a pleading, provided that the same does not subvert the essence of the proceeding and connotes at least a reasonable attempt at compliance with the Rules. After all, rules of procedure are not to be applied in a very rigid, technical sense; they are used only to help secure substantial justice. Given this precedent, it only remains for us to determine if we can apply a liberal construction of the Rules because a meaningful litigation of the case can ensue given the Petition’s prima facie merit.
WHEREFORE, in light of all the foregoing, we
hereby REVERSE and SET ASIDE the Resolutions dated January 28, 2009 and June 11, 2009 of the Special Former Special Division of Five of the Court of Appeals in CA-G.R. SP No. 02436-MIN. The Decision dated November 7, 2007 and Order dated July 1, 2008 of the Regional Trial Court, Branch 31, Dapa, Surigao del Norte are ANNULLED. The Judgment dated May 23, 2007 of the Municipal Circuit Trial Court, Del Carmen-San Isidro-San Benito, Surigao del Norte is REINSTATED. Costs against the plaintiffs-respondents.
Craig Steven Blumhagen, Individually and on Behalf of All Inmates at Wyoming State Penitentiary and Work Release Sites, and Michael S. Langlois William Norris Rudy Hernandez Michael Strauch Gary R. Messer William Goodwine, Also Known as Billy Goodwine George McGlasson David J. Gould, Also Known as Dave Gould Thomas C. Barnett Chris Kantrud Alan Gudmunson Michael Alan Brown Charles Van Duser Keith Curtis Gary Chorniak Sean Frechea Dane Schaible Thomas R. Dilimone Kenneth L. Maynard, and David Doyle Miller, Individually and on Behalf of All Inmates at Wyoming State Penitentiary and Work Release Sites Martin Lofland Joe Fitzgerald Robert Lee Wagoner Perry Espinoza Robert J. Taylor Jack Standley Kevin P. Seavolt Edward F. Ortega Manuel Miramontes Tom Hillman Lauro Valdez Steven B. Jones Jorge Nava Tony Williams Cleo Cooper and Ronald Davis v. Jane Sabes, Individually and in Her Official Capacity as Director of Wyoming Department of Health Corrections Duane Shillinger, Individually and in H