G.R. No. 128772 February 3, 2000
RICARDO C. CADAYONA, petitioner, vs. COURT OF APPEALS and THE PROVINCIAL GOVERNOR OF LEYTE, respondents.

FACTS

Petitioner Ricardo Cadayona filed a Petition for Review with the Court of Appeals to annul Civil Service Commission resolutions affirming his preventive suspension. The appellate court dismissed the petition outright on two procedural grounds: first, the attached certificate of non-forum shopping was executed by his counsel and not by the petitioner himself; and second, three annexes (Annexes D, E, and F) were mere plain copies, not certified true copies. The Court of Appeals denied the motion for reconsideration, ruling that while there was substantial compliance on the forum shopping requirement, the failure to submit certified true copies of the three annexes constituted a fatal flaw warranting dismissal.
Petitioner argued that under the applicable rules (Revised Administrative Circular No. 1-95, now embodied in Rule 43 of the Rules of Court), only the judgment or order appealed from and material portions of the record referred to in the petition need to be certified true copies, not all supporting papers. He invoked the doctrine of last antecedent, contending that the qualifier “certified true copies” refers only to the immediately preceding phrase “such material portions of the record.” He also claimed his failure was excusable as the originals were with the respondent, and he had limited time to secure certified copies after engaging counsel.

ISSUE

Whether the Court of Appeals committed reversible error in dismissing the petition for review due to the submission of uncertified copies of three annexes.

RULING

Yes. The Supreme Court granted the petition, reversed the dismissal, and remanded the case to the Court of Appeals. The legal logic is that procedural rules should not be applied rigidly when it frustrates substantial justice. The Court clarified that while Section 6, Rule 43 requires certified true copies of the judgment appealed from and material portions of the record, the outright dismissal was too severe under the circumstances. The petitioner had substantially complied, as only three out of seven annexes were uncertified, and the certified ones were sufficient for a prima facie determination of the case’s merits. His explanation that the originals of the uncertified annexes were in the respondent’s possession was not rebutted. The Court emphasized that the appellate court should have directed compliance with the rule instead of imposing the drastic penalty of dismissal, especially where no intent to disregard the rules was shown and the defects were curable. The rules of procedure are tools to facilitate, not obstruct, justice.