G.R. No. 196875 , August 19, 2015
Teddy Maravilla, Petitioner, vs. Joseph Rios, Respondent.

FACTS

In 2003, respondent Joseph Rios filed a criminal case for reckless imprudence resulting in serious physical injuries against petitioner Teddy Maravilla before the Municipal Trial Court in Cities (MTCC) of Himamaylan City. The MTCC acquitted Maravilla on December 14, 2006, citing lack of proof beyond reasonable doubt, but ordered him to pay Rios P20,000.00 as temperate damages based on preponderance of evidence. Rios appealed. The Regional Trial Court (RTC), in its Decision dated May 19, 2008, modified the MTCC judgment by deleting the temperate damages and instead ordering Maravilla to pay Rios P256,386.25 as actual and compensatory damages. Maravilla filed a Petition for Review with the Court of Appeals (CA). The CA dismissed the petition in a Resolution dated July 25, 2008, citing defects: (a) failure to incorporate a written explanation for not using a personal mode of filing, and (b) failure to attach relevant pleadings and documents necessary for resolution, such as the information, appellant’s brief, appellee’s brief, and other evidence. Maravilla’s motion for reconsideration was denied by the CA in a Resolution dated April 4, 2011, as he still failed to comply with the requirement to attach supporting documents. Maravilla elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in dismissing the Petition for Review under Rule 42 due to procedural technicalities, specifically for non-compliance with the requirement to attach relevant pleadings and documents.

RULING

The Supreme Court denied the Petition, upholding the CA’s dismissal. The Court ruled that under Section 2(d), Rule 42 of the Rules of Court, a petition for review must be accompanied by copies of pleadings and other material portions of the record that support its allegations. Failure to comply is a sufficient ground for dismissal under Section 3 of the same rule. The Court cited Galvez v. Court of Appeals, which established guideposts for determining the necessity of attached documents, emphasizing that the attached documents must support the material allegations of the petition to make out a prima facie case. The Court found that Maravilla failed to attach essential documents, such as transcripts of stenographic notes and the formal offer of evidence, which were necessary to support his allegations challenging the RTC’s award of actual damages. His submission of some documents with his motion for reconsideration was insufficient and untimely. The Court also noted that Maravilla’s petition involved a re-examination of factual findings, which is not the proper function of a Rule 42 petition, as the CA’s review is limited to questions of law absent any recognized exception. The CA did not commit a reversible error in dismissing the petition for non-compliance with procedural rules.