G.R. No. 234491 , February 26, 2020
KENNETH C. DUREMDES, PETITIONER, V. CAROLINE G. JORILLA, RODOLFO C. DE LEON, MANOLITO SIOSON, ELMER B. GASANG, MICHAEL DE CASTRO, GENNETE E. RIVERA, SYLVIA ORBASE, IRENE MAGSOMBOL, NENITA R. DOMAGUING, AND CHERILYN PALMA, RESPONDENTS.

FACTS

On August 27, 2009, respondents filed a Complaint for Collection of Sum of Money plus Damages against petitioner Kenneth C. Duremdes and Emerflor B. Manginsay, Jr., alleging they were victims of illegal recruitment by Vitamins & Cebu Artists International, Inc. (VCAII), of which petitioner and Manginsay were alleged majority stockholders. Summons was served by publication after which petitioner and Manginsay failed to file their answers. They were declared in default, and respondents presented evidence ex parte. On March 20, 2014, the Regional Trial Court (RTC) rendered a Decision awarding actual and moral damages to respondents. Petitioner filed a Petition for Relief from Judgment on May 22, 2014, arguing the judgment should be set aside on grounds of fraud, alleging respondents knowingly specified an erroneous address preventing proper service of summons, and that respondents committed fraud by filing a separate civil case despite previous criminal cases. The RTC denied the petition on July 21, 2016. Petitioner filed a Petition for Certiorari before the Court of Appeals (CA). The CA dismissed the petition in its Resolution dated July 25, 2017, citing fatal defects: (1) no explanation for not availing of appeal; (2) failure to attach a certified true copy of the RTC Decision dated July 21, 2016 (the attached copy bore only “ORIGINAL SIGNED”) and an illegible photocopy of the March 20, 2014 Decision; and (3) failure to attach copies of pertinent pleadings. The CA denied petitioner’s motion for reconsideration on September 26, 2017.

ISSUE

Whether the Court of Appeals erred in dismissing the Petition for Certiorari based on procedural infirmities.

RULING

Yes. The Supreme Court granted the petition. The Court ruled that the CA erred in dismissing the petition based solely on technicalities. Petitioner substantially complied with the formal requirements for a petition for certiorari. The subsequent submission of the required documents with the motion for reconsideration before the CA amounted to substantial compliance. The Court emphasized that rules of procedure should be applied to secure justice, not defeat it, and that subsequent and substantial compliance may call for the relaxation of procedural rules. The case was remanded to the CA for further proceedings.