G.R. No. 241385 , July 07, 2020
Spouses Mariano Cordero and Raquel Cordero, Petitioners, vs. Leonila M. Octaviano, Respondent.

FACTS

In 2011, respondent Leonila Octaviano, the registered owner of a land, filed a complaint for ejectment against petitioners Spouses Mariano and Raquel Cordero before the Municipal Circuit Trial Court (MCTC). On May 22, 2013, the MCTC ruled in favor of Leonila. The Spouses Cordero appealed to the Regional Trial Court (RTC), which affirmed the MCTC’s findings on December 7, 2016. Their motion for reconsideration was denied by the RTC on June 22, 2017. Aggrieved, the Spouses Cordero elevated the case to the Court of Appeals (CA) through a petition for review. On December 19, 2017, the CA dismissed the petition due to procedural defects: (1) failure to state the material date of receipt of the December 7, 2016 RTC Decision, and (2) failure to append clearly legible duplicate originals or true copies of the assailed decision and other necessary records, as required under Rule 42 of the Rules of Court. The Spouses Cordero sought reconsideration, arguing substantial compliance, noting that the petition indicated the date of receipt of the June 22, 2017 RTC Order denying their motion for reconsideration, and that copies of the RTC Decision, RTC Order, and MCTC Decision were attached. They also subsequently submitted additional records. On June 29, 2018, the CA denied their motion for reconsideration, deeming it filed one day late. The Spouses Cordero filed this Petition for Review on Certiorari, arguing their motion for reconsideration was timely filed on February 1, 2018, as evidenced by an affidavit, registry receipt, and postmaster’s certification, and that a rigid application of technicalities should not prevail over substantial justice.

ISSUE

Whether the Court of Appeals committed a gross error in outrightly dismissing the petition for review based on procedural defects, warranting the liberal application of the rules of procedure in the interest of substantial justice.

RULING

Yes, the Supreme Court granted the petition. The Court ruled that the CA’s outright dismissal constituted a gross error and contravened the Spouses Cordero’s right to be heard on appeal. The circumstances merit the liberal application of procedural rules to prevent a grave injustice. First, regarding the failure to state the material date of receipt of the December 7, 2016 RTC Decision, the Court held that the more material date for appeal is the date of receipt of the order denying the motion for reconsideration. Since the petition clearly stated they received the June 22, 2017 RTC Order on July 11, 2017, and filed the petition within the 15-day reglementary period on July 26, 2017, this was substantial compliance. Second, regarding the alleged failure to submit material records, the Court found that copies of the RTC Order (Annex “A”), MCTC Decision (Annex “B”), and RTC Decision (Annex “C”) were in fact attached to the petition, which were sufficient for the CA to resolve the appeal, and the Spouses Cordero later appended pertinent pleadings in their motion for reconsideration. Third, regarding the timeliness of the motion for reconsideration before the CA, the Court found it was filed on time on February 1, 2018, by registered mail, as established by the supporting documents; the date of mailing is considered the date of filing under the rules. The case was remanded to the CA with instructions to reinstate and give due course to the petition for a resolution on the merits.