GR 183467; (March, 2010) (Digest)

G.R. No. 183467, March 29, 2010
EVELYN BARREDO, Petitioner, vs. PEOPLE OF THE PHILIPPINES, HON. FRANCISCO F. MACLANO, Presiding Judge, Regional Trial Court of Butuan City, Br. 3, and ATTY. RICARDO GONZALEZ, Respondents.

FACTS

Evelyn Barredo (petitioner) was charged with perjury before the Municipal Trial Court in Cities (MTCC) of Butuan City for allegedly making an untruthful statement in her affidavit-complaint for usurpation of authority and illegal detention against Atty. Ricardo D. Gonzalez. The statement accused Gonzalez of “usurp[ing] police functions” by instructing police to impound her truck and detain her helpers after a vehicular mishap. The MTCC convicted Barredo of perjury, sentencing her to imprisonment and ordering her to pay moral damages. The Regional Trial Court (RTC) affirmed the MTCC decision. Barredo filed a petition for review with the Court of Appeals, which dismissed it outright for failure to attach a copy of the MTCC decision. Her motion for reconsideration was denied, prompting this Petition for Review on Certiorari. Barredo contends her petition should be reinstated as she attached the RTC decision, which verbatim restated the MTCC’s findings. The Solicitor General supported reinstatement in the interest of substantial justice, while the private complainant filed a conditional “Motion to Dismiss” expressing willingness to forego the complaint if Barredo committed not to file any further suits.

ISSUE

Whether the Court of Appeals committed reversible error in dismissing Barredo’s petition for review due to her failure to attach a copy of the MTCC decision, despite attaching the RTC decision that affirmed the MTCC’s findings verbatim.

RULING

Yes, the Court of Appeals committed reversible error. While Rule 42, Section 2(d) of the 1997 Rules of Civil Procedure requires petitions for review to be accompanied by copies of the judgments of both lower courts, the deficiency did not render Barredo’s petition insufficient in form and substance. The subject of her appeal was the RTC decision, not the MTCC decision. The attached RTC decision extensively quoted and affirmed the MTCC’s findings and legal discussion. Citing Silverio v. Court of Appeals, the Supreme Court emphasized that procedural rules should facilitate substantial justice, not frustrate it, especially in criminal cases where liberty is at stake. The failure to attach the MTCC decision did not adversely affect the petition’s sufficiency, as the RTC decision sought to be reviewed was attached. The private complainant’s “Motion to Dismiss” was deemed a mere scrap of paper for lacking a proper prayer and setting conditions. The Court reversed the Court of Appeals’ resolutions, reinstated Barredo’s petition, and directed the Court of Appeals to act on it with dispatch.