GR 190998; (July, 2015) (Digest)
G.R. No. 190998, July 20, 2015.
Spouses Robert C. Paderanga and Jovita M. Paderanga, Petitioners, vs. Spouses Pendatun A. Bogabong and Norma P. Bogabong; Stalingeorge Paderanga and the Register of Deeds of Iligan City; Cipriano Ratunil; Antonio Miñoza; Heirs of Tomas Tan Sr., Lourdes Tan and Liben Go Medina, Respondents.
FACTS
Petitioners filed a Complaint for Injunction, Declaration of Nullity of forged Power of Attorney, etc., with the Regional Trial Court (RTC) of Iligan City against respondents. The core issue was the genuineness of petitioner Robert Paderanga’s signature on a Special Power of Attorney (SPA) that purportedly authorized respondent Stalingeorge Paderanga to sell a tract of land. The RTC ruled in favor of respondents, declaring the signature genuine and dismissing the complaint. Petitioners appealed to the Court of Appeals (CA). After being granted extensions totaling ninety (90) days to file their appellants’ brief, petitioners still filed it belatedly. Consequently, the CA issued a Resolution deeming the appeal abandoned and dismissed it, noting that a prior extension had been granted with a warning that no further motions would be entertained. The CA denied the motion for reconsideration.
ISSUE
Whether the Court of Appeals erred in dismissing petitioners’ appeal due to the belated filing of the appellants’ brief, thereby warranting a remand of the case to the CA for resolution on the merits.
RULING
The Supreme Court GRANTED the petition and REMANDED the case to the Court of Appeals for proper disposition. The Court held that while expeditious administration of justice is important, it should not override the higher interest of just resolution on the merits. Unless non-compliance with procedural rules is wantonly, deliberately vexatious, and dilatory, premium should be given to the substantive rights of litigants. Citing Villanueva v. People, the Court emphasized that procedural infirmities take a backseat against substantive rights. Petitioners should be given the opportunity to fully argue the substantial issues, which include the authenticity of the SPA signature, the credibility of a handwriting expert, the validity of the deed of sale, whether respondents are innocent purchasers for value, propriety of partition, and claims for damages. Since a petition for review on certiorari under Rule 45 only entertains questions of law, these substantive issues must first be threshed out in the appellate court.