GR 140436; (July, 2000) (Digest)
G.R. No. 140436; July 18, 2000
CORNELIA P. CUSI-HERNANDEZ, petitioner, vs. Spouses EDUARDO DIAZ and AMELIA MANGAHAS, respondents.
FACTS
Petitioner Cornelia Cusi-Hernandez filed an accion publiciana before the Municipal Trial Court (MTC) of Norzagaray, Bulacan against respondents spouses. She alleged being the registered owner of a property covered by OCT No. T-2435. The parties had entered into a Contract to Sell a portion of the land, but respondents allegedly defaulted on their installment payments. After a notarized letter of rescission was sent and respondents failed to vacate, the suit was instituted. The MTC ruled in favor of the petitioner, but the Regional Trial Court (RTC) reversed this decision on appeal. Petitioner then filed a Petition for Review with the Court of Appeals (CA).
ISSUE
Whether the Court of Appeals erred in dismissing the Petition for Review due to an alleged failure to attach certified true copies of material portions of the record, as required under Section 2, Rule 42 of the 1997 Rules of Civil Procedure.
RULING
Yes. The Supreme Court reversed the CA’s dismissal. The Court clarified that while Section 2, Rule 42 requires a petition to be accompanied by certified true copies or duplicate originals of the assailed judgments or final orders, the rule does not mandate that all other supporting papers must likewise be certified true copies. The requirement is for “clearly legible duplicate originals or true copies” of other material portions of the record. In this case, the Contract to Sell, a central document, was reproduced verbatim in the MTC Decision, a duplicate original of which was properly attached to the Petition. Furthermore, a certified true copy of the Contract was subsequently submitted with the Motion for Reconsideration. The appellate court thus exercised its discretion too rigidly. The Court emphasized that rules of procedure are tools to facilitate, not frustrate, the attainment of justice. Technicalities that hinder substantial justice must be avoided. Consequently, the Supreme Court granted the Petition, set aside the CA Resolutions, and remanded the case to the CA for a decision on the merits.