GR 191837; (September, 2012) (Digest)
G.R. No. 191837; September 19, 2012
MARIA CONSOLACION RIVERA-PASCUAL, Petitioner, vs. SPOUSES MARILYN LIM and GEORGE LIM and the REGISTRY OF DEEDS OF VALENZUELA CITY, Respondents.
FACTS
The case involves a parcel of agricultural land in Valenzuela City. Petitioner Maria Consolacion Rivera-Pascual filed a petition before the Regional Agrarian Reform Adjudicator (RARAD) to be recognized as a tenant by succession. The land was originally owned by Danilo Deato, who sold it to respondent Spouses Lim during the pendency of the case. The RARAD granted the petition, declaring Consolacion a tenant and ordering the Spouses Lim, as successors-in-interest, to maintain her in possession. The decision became final. Consolacion then filed a separate petition to exercise her right of redemption under agrarian laws, consigned ₱10 million, and secured a favorable RARAD decision ordering the Spouses Lim to accept the redemption. The Spouses Lim appealed to the Department of Agrarian Reform Adjudication Board (DARAB), which reversed the RARAD, declaring the land not lawfully redeemed and Consolacion not a bona fide tenant. Consolacion’s motion for reconsideration was denied for being filed out of time.
Consolacion subsequently filed a Petition for Review under Rule 43 with the Court of Appeals (CA). The CA required her counsel to submit his Mandatory Continuing Legal Education (MCLE) Certificate of Compliance and an amended Verification and Certification Against Non-Forum Shopping within five days. Counsel failed to comply. The CA dismissed the petition for failure to comply with these procedural requirements. Consolacion’s motion for reconsideration was likewise denied.
ISSUE
Whether the Court of Appeals correctly dismissed the petition for review due to petitioner’s counsel’s failure to comply with procedural requirements regarding the MCLE certificate and the verification and certification against forum shopping.
RULING
Yes, the Supreme Court affirmed the CA’s dismissal. The Court emphasized that procedural rules are not to be disregarded. While litigation should be decided on merits, compliance with rules is mandatory. The requirement to attach an MCLE certificate and a proper verification and certification against forum shopping is crucial. The former ensures the counsel is authorized to practice, and the latter is essential to prevent forum shopping and ensure truthfulness of allegations.
Petitioner’s counsel offered only claims of inadvertence and negligence without providing a satisfactory explanation for the non-compliance. The Court held that liberal construction of procedural rules is not a right but an exception granted only upon a showing of compelling reasons. The burden lies on the party seeking leniency to prove they deserve exceptional treatment. Here, no valid justification was presented. The negligence of counsel binds the client. The Court cannot condone a cavalier attitude towards procedural rules, as they are designed to ensure orderly administration of justice. Consequently, the petition was properly dismissed for failure to adhere to mandatory procedural requirements.