G.R. No. 144560 . April 13, 2004.
FLORENTINO ZARAGOZA, petitioner, vs. PEDRO NOBLEZA, respondent.

FACTS

Petitioner Florentino Zaragoza, a landowner, filed a complaint before the Provincial Agrarian Reform Adjudicator (PARAD) seeking the termination of his agricultural leasehold contract with respondent Pedro Nobleza. Zaragoza alleged multiple infractions, including non-payment of lease rentals, neglect of the landholding, and commission of crimes such as qualified theft and attempted murder. The PARAD dismissed the complaint for lack of merit. The Department of Agrarian Reform Adjudication Board (DARAB) affirmed this dismissal.
Zaragoza received the DARAB decision on February 29, 2000. He filed a motion for a 15-day extension with the Court of Appeals (CA), which was granted with a strict deadline of March 30, 2000. Zaragoza filed his petition for review via registered mail. The CA dismissed the petition, finding it was mailed on April 12, 2000, 13 days late, and that it contained annexes that were mere plain copies, violating procedural rules. Zaragoza moved for reconsideration, submitting a postal certification claiming a March 30 mailing date, but the CA denied it, noting the certification was unsworn and contradicted by the postmark on the copy received by respondent’s counsel.

ISSUE

Whether the Court of Appeals committed reversible error in dismissing the petition for review on purely procedural grounds.

RULING

The Supreme Court denied the petition and affirmed the CA’s resolutions. The ruling is based on the paramount importance of procedural rules and the absence of compelling justification for their relaxation. The Court found the CA correctly applied Section 6(c), Rule 43 of the Rules of Court, which requires material portions of the record to be certified true copies. The two unverified Informations for qualified theft and attempted murder were deemed material as they pertained directly to the alleged grounds for leasehold termination.
On the issue of timeliness, the Court upheld the CA’s factual finding that the petition was filed late. The postal certification presented by Zaragoza was correctly accorded little weight as it was unsworn and effectively rebutted by the contrary evidence—the April 12 postmark on the copy received by adverse counsel. The Court emphasized that rules of procedure are not to be disregarded lightly. For liberality to apply, a litigant must demonstrate a compelling reason and that the cause is not entirely devoid of merit. Zaragoza failed on both counts. The substantive issues he raised involved factual determinations by the PARAD and DARAB. Under Rule 45 of the Rules of Court, only questions of law are reviewable by the Supreme Court in a petition for review on certiorari. Factual findings of administrative agencies, when supported by substantial evidence, are conclusive. No exceptional circumstance warranting a deviation from this rule was shown. Thus, the dismissal on procedural grounds was proper.