GR L 16854; (December, 1963) (Digest)
G.R. No. L-16854 December 26, 1963
PATROCINIO QUIBUYEN, SERVILLANO QUIBUYEN, AND JOSE V. KAYANAN, petitioners, vs. THE COURT OF APPEALS, JUDGE HIGINIO MACADAEG, in his capacity as Presiding Judge of Br. X, CFI of Manila, RIZALINA T. PULIDO and PANTALEON PULIDO, respondents.
FACTS
Petitioners were defendants in a civil case where a default judgment was rendered against them. Their subsequent “Petition for Relief from Judgment” was denied by the trial court on January 5, 1959. Their appeal from this denial was also rejected by the trial court in an Order dated April 27, 1959. Petitioners then filed a petition for certiorari with the Court of Appeals, assailing the April 27, 1959 Order. The Court of Appeals dismissed the petition, finding it fatally defective for failure to attach supporting papers as required by Section 2, Rule 49 of the Rules of Court. Specifically, the appellate court noted the absence of the January 5, 1959 Order denying the petition for relief. Petitioners filed a motion for reconsideration, attaching the missing documents and explaining the omission was a clerical mistake, but the motion was denied.
ISSUE
Whether the Court of Appeals erred in dismissing the petition for certiorari on the sole ground of procedural deficiency for non-attachment of supporting papers.
RULING
Yes, the Supreme Court reversed the dismissal. The Court held that while procedural rules require the attachment of relevant orders and pleadings, their subsequent submission with the motion for reconsideration substantially complied with this requirement and cured the initial defect. The core order being assailed—the April 27, 1959 Order refusing to give due course to the appeal—was in fact attached to the original petition. The rules of procedure should be liberally construed to afford litigants ample opportunity to prove their claims and to avoid the denial of substantial justice due to technicalities. The dismissal based on a formal, curable defect was therefore unjustified. The case was remanded to the Court of Appeals for proceedings on the merits of the certiorari petition. The Supreme Court refrained from discussing the substantive merits of the underlying appeal, as that was a matter for the appellate court to resolve once the petition was properly given due course.