GR 143156; (January, 2003) (Digest)
G.R. No. 143156. January 13, 2003.
TEDDY MOLINA, JULIET PASCUAL, ISAGANI YAMBOT, and LETTY JIMENEZ-MAGSANOC, petitioners, vs. HON. COURT OF APPEALS and RAYMUNDO A. ARMOVIT, respondents.
FACTS
Petitioners Teddy Molina and Juliet Pascual authored news articles published in the Philippine Daily Inquirer on May 2 and 3, 1996, stating that convicted killer Rolito Go was hiding at a vacation house in San Fernando, La Union, owned by his lawyer, private respondent Raymundo Armovit. Armovit filed a libel complaint. The Provincial Prosecutor found probable cause and filed Informations. Petitioners sought a review, and the Office of the Regional State Prosecutor reversed the finding and directed the withdrawal of the Informations. The Regional Trial Court (RTC) of Vigan, Ilocos Sur, Branch 21, denied the motion to withdraw, finding probable cause. Petitioners filed a special civil action for certiorari with the Court of Appeals (CA). The CA dismissed the petition due to procedural defects: failure to include certified true copies of the RTC orders showing the authority of the certifying officer and a clear court seal, failure to attach all pertinent pleadings and documents, and failure to implead the RTC judge as a nominal party. Petitioners’ motion for reconsideration was denied.
ISSUE
Did the Court of Appeals commit a reversible error of law in dismissing the petition for certiorari on mere technicalities?
RULING
Yes. The Supreme Court reversed the CA resolutions. The Rules of Court should be liberally construed to secure a just, speedy, and inexpensive disposition. Petitioners could not be faulted for defects in the certification of the RTC orders, as they had no control over their preparation and could rely on the presumption that official duty was regularly performed. The failure to attach all pleadings and documents was not a sufficient ground for dismissal, as it did not involve public policy, prejudice the adverse party, or deprive the court of its authority. Furthermore, impleading the trial judge is not required under Rule 65, Section 1; naming the tribunal (the RTC) as a nominal party substantially complies with the rule. The CA erred in stressing technicalities over the merits. The petition was granted, and the CA was directed to reinstate the petition for certiorari.