GR 156800; (November, 2004) (Digest)
G.R. No. 156800 ; November 25, 2004
ISIDORO A. PADILLA, JR., CLARA RITA A. PADILLA, and JOSEPH HALDOS, petitioners, vs. LUIS ALIPIO, MILAGROS ALIPIO, and all other persons claiming rights under them, respondents.
FACTS
Petitioners Isidoro Padilla, Jr., Clara Rita Padilla, and Joseph Haldos filed an ejectment suit against respondent spouses Luis and Milagros Alipio before the Metropolitan Trial Court (MeTC) of Quezon City. Petitioners claimed to be the lawful possessors of a property in Pingkian Village, Quezon City, and alleged that the respondents illegally usurped possession in 1998. The respondents countered that petitioners had no right to the property, as they were among the defendants in a prior ejectment case (Civil Case No. 7608) filed by the registered owners, the spouses Barba. In that prior case, a final judgment had been rendered ordering the eviction of the defendants, including petitioner Isidoro Padilla, Jr.
The MeTC dismissed petitioners’ complaint, declaring they had no right to possession based on the final judgment in the prior ejectment case, and awarded damages to the respondents. The Regional Trial Court (RTC) affirmed the decision on appeal. Petitioners then filed a petition for review with the Court of Appeals.
ISSUE
Did the Court of Appeals commit reversible error in dismissing outright the petition for review for alleged non-compliance with Section 2, Rule 42 of the 1997 Rules of Civil Procedure?
RULING
Yes. The Supreme Court ruled that the Court of Appeals committed reversible error in dismissing the petition for review on a technicality. The appellate court dismissed the petition because it was “not accompanied by true copies of the pleadings and other material portions of the record as would support the allegations of the petition,” as required by Section 2, Rule 42.
The Supreme Court found that petitioners had substantially complied with the rule. The petition annexed certified true copies of the RTC Decision and the Order denying reconsideration, which are the judgments subject of the review. The failure to attach a certified copy of the MeTC decision was not fatal, as the RTC decision, which was attached, affirmed the MeTC decision in toto and even quoted it verbatim. Furthermore, the petition itself quoted material portions of the pleadings and records from the lower courts. The Court emphasized that rules of procedure are tools to facilitate justice, not to frustrate it. Dismissing appeals on purely technical grounds is frowned upon when it would result in manifest injustice, especially where there has been substantial compliance. The case was remanded to the Court of Appeals for a decision on the merits.