GR 133542; (January, 2004) (Digest)
G.R. No. 133542; January 29, 2004
FRANCISCO DEE, represented by FORTUNATO T. DEE, Petitioner, vs. COURT OF APPEALS, HON. REYNALDO G. ROS, Presiding Judge, Branch 80, RTC, Morong, Rizal, and RODOLFO TINGSON, Respondents.
FACTS
Petitioner Francisco Dee filed a forcible entry case against respondent Rodolfo Tingson before the Municipal Trial Court (MTC) of Morong, Rizal. Dee alleged he was the registered owner of a parcel of land and that Tingson, with force and stealth, entered and fenced a portion of it in January 1996. Tingson claimed the fenced area was part of lots he had been occupying and for which he had applied for a free patent, asserting it did not adjoin Dee’s land except at one corner. The MTC ruled in favor of Dee, ordering Tingson to vacate and pay damages. Tingson appealed to the Regional Trial Court (RTC), which reversed the MTC decision. Dee then filed a petition for review with the Court of Appeals (CA).
The CA dismissed Dee’s petition outright for failure to comply with Section 2, Rule 42 of the Rules of Court. The CA found that Dee did not attach the required certified true copies of the material portions of the record, specifically the MTC and RTC decisions and the RTC order denying his motion for reconsideration. Dee moved for reconsideration, arguing the attached copies were legible and sufficient, but the CA denied the motion.
ISSUE
Whether the Court of Appeals erred in dismissing the petition for review based solely on a procedural technicality.
RULING
Yes, the Supreme Court granted the petition and remanded the case to the CA. The Court emphasized that while procedural rules are designed to facilitate the orderly administration of justice, they are not to be applied rigidly if they defeat substantial justice. The rule of liberal construction under Rule 1, Section 6 of the Rules of Court mandates that rules be construed to promote a just, speedy, and inexpensive disposition of every action.
The Court found that the appended copies of the MTC and RTC decisions and the RTC order in the petition were legible and sufficient for the CA to ascertain the facts and resolve the issues. More importantly, the petition raised a substantive issue regarding the application of the Rules on Summary Procedure and whether the RTC correctly reversed the MTC. Dismissing the appeal on a technicality would preclude a resolution on the merits. The settled doctrine is that litigations should be decided on their merits, and every party must be afforded a full opportunity to be heard. Technicalities should not hinder the court’s duty to resolve genuine controversies. The proper course was for the CA to have given due course to the petition and resolved the substantive issues presented.