GR 222798; (June, 2019) (Digest)
G.R. No. 222798 June 19, 2019
Alfredo Pili, Jr., Petitioner vs. Mary Ann Resurreccion, Respondent
FACTS
Respondent Mary Ann Resurreccion purchased a house and lot from Conpil Realty Corporation and issued two checks as payment. The checks were dishonored upon deposit. A criminal complaint for violation of Batas Pambansa Blg. 22 was filed before the Municipal Trial Court (MTC). Although the checks were issued in favor of Conpil, the complaint was signed by its President, petitioner Alfredo Pili, Jr., in a representative capacity. Supporting documents, including a Secretary’s Certificate, were presented to prove his authority to act for the corporation.
The MTC acquitted respondent of the criminal charge but ordered her to pay Conpil the civil indemnity of PHP 500,000, representing the face value of the check. Respondent appealed the civil aspect to the Regional Trial Court (RTC), which affirmed the MTC. On further appeal, the Court of Appeals (CA) reversed the RTC. The CA ruled that the criminal case was not prosecuted in the name of the real party in interest, as the case title was “People v. Resurreccion” and the complaint was signed by Pili, not Conpil. The CA held this omission fatal, dismissing the civil liability order without prejudice to a separate action by the real party.
ISSUE
Whether the Court of Appeals erred in dismissing the civil liability aspect on the ground that the criminal complaint was not prosecuted in the name of the real party in interest.
RULING
Yes. The Supreme Court reversed the CA, emphasizing that pleadings should be construed liberally to achieve substantial justice, with the least regard for technicalities. The Court cited Vlason Enterprises Corp. v. Court of Appeals, which holds that while including all parties’ names in a complaint’s title is a formal requirement under the rules, the averments in the body of the complaint are controlling. The failure to include a party’s name in the title is not fatal if the body indicates that the party was made part of the action.
Here, the records clearly showed that petitioner Pili instituted the action solely as the authorized representative of Conpil Realty Corporation. The Secretary’s Certificate and the Affidavit of Complaint formally offered in evidence substantiated that he was acting on behalf of the corporation, the undisputed payee of the dishonored checks. The CA focused unduly on the case caption and the signatory, ignoring the substance of the pleadings and the evidence proving representative authority. Therefore, the real party in interest, Conpil, was properly represented, and the civil liability adjudged by the MTC was valid. The case was remanded to the CA to resolve the appeal on the merits with dispatch.