GR 160420; (July, 2005) (Digest)
G.R. No. 160420 . July 28, 2005.
DANIEL ANINAO, ET AL., petitioners, vs. ASTURIAS CHEMICAL INDUSTRIES, INC., respondent.
FACTS
The case involves 507 hectares of land in Calatagan, Batangas, formerly owned by Ceferino Ascue. In 1989-1990, Emancipation Patents (EPs) were issued to 323 farmer-beneficiaries under the agrarian reform program. The Land Bank of the Philippines set aside compensation for Ascue. In 1995, the heirs of Ascue, with court approval, sold the entire 807-hectare property, which included the subject land, to respondent Asturias Chemical Industries, Inc. Years later, Asturias sought exemption from CARP coverage, arguing the land was mineral and unsuitable for agriculture. The DAR Regional Director granted an exemption for 284 hectares. The petitioners, the farmer-beneficiaries, challenged this exemption.
The petitioners filed a petition for review with the Court of Appeals (CA) to nullify the DAR exemption order. The CA dismissed their petition outright due to procedural defects, specifically their failure to attach a sworn certification against forum shopping as required by the Rules of Court. The petitioners moved for reconsideration, which the CA denied. They then elevated the case to the Supreme Court via a petition for review on certiorari.
ISSUE
The core issue is whether the Court of Appeals correctly dismissed the petition for review on the ground of the petitioners’ failure to comply with the requirement of a sworn certification against forum shopping.
RULING
The Supreme Court denied the petition and affirmed the CA’s dismissal. The Court held that the requirement to submit a sworn certification against forum shopping is mandatory. Non-compliance is a sufficient ground for the dismissal of the petition. The petitioners’ failure to attach this certification to their CA petition was a fatal procedural flaw that warranted the dismissal of their case. The Court emphasized that procedural rules are not mere technicalities but are essential to the orderly administration of justice and the prompt resolution of cases.
While the Court acknowledged the substantive importance of the agrarian reform issues raised, it stressed that strict adherence to procedural rules is necessary. The petitioners’ procedural misstep prevented a review of the merits of the DAR’s exemption order. The ruling underscores that the right to appeal is a statutory privilege that must be exercised in accordance with the prescribed procedure. Consequently, the CA’s resolutions dismissing the petition were upheld.