G.R. No. 238761 . January 22, 2020.
GOOD EARTH ENTERPRISES, INC., PETITIONER, VS. DANILO GARCIA, JUANITA FAJUTAG, LEONOR GONZALES, RIZAL MEJULIO, ARLENE GUEVARRA, EDWIN MENDOZA, LEONIDA SANCHO, ANALIZA SERILANO, DOMINGO ROCIENTO, RICO GUEVARRA, RUFINO JALMASCO, AND RAUL BORLADO, JR., RESPONDENTS.

FACTS

Petitioner Good Earth Enterprises, Inc. filed an Amended Complaint for ejectment (unlawful detainer) against respondents before the Metropolitan Trial Court (MeTC). Petitioner alleged it was the registered owner of a parcel of land. After a prior case (Baltazar v. Court of Appeals) involving the property attained finality, petitioner discovered that a lessee, Classic Realty and Management Corporation (CRMC), had sub-leased portions to respondents. Petitioner “tolerated” respondents’ stay during subsequent legal battles. After winning, petitioner sent demand letters to respondents in May and July 2011 to vacate, which were unheeded, prompting the complaint. Respondents sought dismissal, arguing the MeTC lacked jurisdiction because: (a) the Verification and Certificate of Non-Forum Shopping (CNFS) was signed by Mr. Stephen Hontiveros without a Secretary’s Certificate proving his authority; and (b) the complaint failed to allege petitioner’s prior physical possession. The MeTC ruled for petitioner, ordering respondents to vacate and pay compensation. The Regional Trial Court (RTC) affirmed. The Court of Appeals (CA) reversed and dismissed the complaint solely on the procedural ground that Hontiveros was not duly authorized to sign the verification and CNFS, as no Secretary’s Certificate was initially attached, and petitioner did not attempt to comply.

ISSUE

Whether or not the CA correctly dismissed petitioner’s complaint for unlawful detainer on the purely procedural ground of non-compliance with the rules on verification and certification against forum shopping.

RULING

The Supreme Court granted the petition, reversing and setting aside the CA’s Decision and Resolution. The Court held that the CA erred in dismissing the complaint. Contrary to the CA’s finding, petitioner had belatedly submitted a Secretary’s Certificate (dated August 12, 2011) confirming Hontiveros’ authority to file complaints and sign verifications and certifications on behalf of petitioner. This certificate was filed via a Manifestation dated January 2, 2012, with the MeTC, explaining the initial omission was due to inadvertence, and was later marked and made part of the records. The belated submission constituted substantial compliance with the rules, as it operates to ratify and affirm the delegate’s authority. Therefore, Hontiveros was duly authorized. Since the CA dismissed the case on a purely procedural ground, the Supreme Court remanded the case to the CA for a resolution on the merits.