G.R. No. 188360 ; January 21, 2010
SPS. HEBER & CHARLITA EDILLO, Petitioners, vs. SPS. NORBERTO & DESIDERIA DULPINA, Respondents.

FACTS

On February 21, 2006, respondents Spouses Dulpina filed a Complaint for Forcible Entry against petitioners Spouses Edillo with the Municipal Circuit Trial Court (MCTC). The Dulpinas alleged they purchased a residential lot and house through a Deed of Sale dated May 14, 1990. On August 8, 2005, Heber Edillo, without consent and against express prohibition, fenced off and occupied a 50-square meter portion of the property. A notice to vacate was sent on January 26, 2006, but the Edillos refused. In their Answer, the Edillos countered that the Complaint failed to allege prior physical possession and claimed they acquired the property through three separate Deeds of Absolute Sale from other individuals. On May 23, 2007, the MCTC dismissed the Complaint and ordered the Dulpinas to pay damages and attorney’s fees. The Dulpinas received the judgment on May 31, 2007, filed a Motion for Reconsideration on June 5, 2007 (which was denied on June 8, 2007), and then filed a Notice of Appeal on July 30, 2007, which the MCTC granted. The Regional Trial Court (RTC), on appeal, set aside the MCTC judgment on November 7, 2007, ordered the Edillos to vacate, and awarded attorney’s fees to the Dulpinas. After the RTC denied their Motion for Reconsideration, the Edillos elevated the case to the Court of Appeals (CA) via a Petition for Review under Rule 42, arguing the Dulpinas’ appeal to the RTC was filed out of time because a motion for reconsideration is a prohibited pleading under the Revised Rules of Summary Procedure (RRSP). The CA dismissed the Petition outright in its Resolution dated January 28, 2009, for failure to state the factual background of the case, a violation of Sections 2 and 3 of Rule 42. The CA denied the Motion for Reconsideration and to admit an Amended Petition on June 11, 2009. The Edillos then filed the present Petition for Review on Certiorari under Rule 45.

ISSUE

Whether the Court of Appeals erred in outrightly dismissing the Petition for Review for failure to state the factual background of the case, and whether the appeal to the RTC was filed on time given the prohibition against a motion for reconsideration under the Revised Rules of Summary Procedure.

RULING

The Supreme Court ruled for the petitioners, Spouses Edillo. The Court found that the CA’s outright dismissal was unwarranted. While non-compliance with the requirements of Rule 42 is a ground for dismissal, procedural rules should be liberally construed to secure a just, speedy, and inexpensive disposition of every action. The Court noted that the factual background could be found within the four corners of the petition and its incorporated annexes, constituting substantial compliance. More importantly, a preliminary assessment showed the appeal was prima facie meritorious. The core issue was whether the RTC had jurisdiction over the Dulpinas’ appeal. The case originated as an action for forcible entry, governed by the Revised Rules of Summary Procedure, which prohibits the filing of a motion for reconsideration. The Dulpinas filed their Motion for Reconsideration on June 5, 2007, and their Notice of Appeal on July 30, 2007, beyond the 15-day reglementary period to appeal from the May 31, 2007 receipt of the MCTC judgment. Since the prohibited motion for reconsideration did not toll the running of the appeal period, the MCTC Decision had become final and executory. Consequently, the RTC had no jurisdiction to entertain the appeal. The Supreme Court reversed the CA Resolutions and reinstated the MCTC Decision dismissing the Complaint for Forcible Entry.