G.R. No. 219510 . November 14, 2016. MARLON CURAMMENG y PABLO, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS

Petitioner Marlon Curammeng was convicted by the Municipal Trial Court (MTC) of Reckless Imprudence Resulting in Homicide. The prosecution established that while driving a bus, he struck and killed Francisco Franco, a driver of a stalled bus parked on the opposite lane. Curammeng claimed he decelerated upon seeing the stalled vehicle, but a closed van suddenly appeared, forcing him to swerve, which resulted in the accident. The MTC found his claim of deceleration inconsistent with evidence indicating he was still traveling at about 60 kph, and noted his failure to observe barangay tanods managing traffic near the scene. The Regional Trial Court (RTC) affirmed the conviction, emphasizing his duty as a professional driver to exercise heightened precaution, especially in a poorly lit area where his view was partially obstructed.
Curammeng elevated his case to the Court of Appeals (CA) via a petition for review under Rule 42. The CA dismissed the petition outright due to procedural deficiencies, specifically the failure to attach a certification of non-forum shopping and material portions of the record, such as affidavits and transcripts. His motion for reconsideration, which included the omitted documents and cited his counsel’s secretary’s oversight, was denied. The CA found no compelling reason for a liberal application of the rules.

ISSUE

Whether the Court of Appeals correctly dismissed Curammeng’s petition for review based on procedural grounds.

RULING

No. The Supreme Court reversed the CA’s resolutions and remanded the case for a resolution on the merits. The Court acknowledged that while compliance with procedural rules is mandatory, a liberal application is warranted under exceptional circumstances to serve substantial justice. In this case, the procedural lapses—the failure to attach the certification and certain records—were not attributable to Curammeng himself but to a simple oversight by his counsel’s secretary. More importantly, the Court emphasized the fundamental consideration that the case involves a criminal conviction where the petitioner’s liberty is at stake.
The Court ruled that technicalities should not prevail over the right to appeal, especially in criminal cases where an appeal opens the entire case for review on its merits. The dismissal of an appeal based solely on procedural grounds, where the lapse is not deliberate and no intent to delay is apparent, unduly sacrifices justice for technicality. Given the circumstances, the Court deemed it appropriate to relax the rules to afford Curammeng a full opportunity to argue the substantive merits of his conviction, rather than forfeit his liberty due to a procedural error he did not personally commit.