G.R. No. 244657, February 12, 2024
MICHAEL G. VALENCIA, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioner Michael G. Valencia was charged with adultery under Article 333 of the Revised Penal Code. The Information alleged that on or about December 2001 in General Santos City, Rubirosa M. Ciocon, who was married to Ramon Chito A. Ciocon, willfully had sexual intercourse with Valencia, who knew her to be married. Valencia pleaded not guilty, while Rubirosa remained at large.
The prosecution presented Ramon, the husband, who testified that he discovered his wife Rubirosa was in a relationship with Valencia, a customer at her karinderya. Their daughter, Monaby, testified that she witnessed Valencia and her mother frequently hugging and kissing. Specifically, when she was eight years old, she saw them together in bed, hugging and kissing in their house at Countryside Subdivision. After the family moved to Summerlight Subdivision, she again saw them naked in the bedroom, with Rubirosa on top of Valencia. Valencia denied any sexual relations with Rubirosa.
The Metropolitan Trial Court in Cities (MTCC) found Valencia guilty of adultery based on strong circumstantial evidence, primarily Monaby’s testimony, and sentenced him to prision correccional. The MTCC noted it could not consider acts alleged in Polomolok, South Cotabato, as it was beyond its territorial jurisdiction. The Regional Trial Court (RTC) affirmed the conviction. Valencia appealed to the Court of Appeals, which dismissed the appeal due to procedural defects, including non-payment of correct docket fees, failure to furnish the Office of the Solicitor General a copy, lack of a written explanation for service by mail, defective verification, and failure to append material documents. His motion for reconsideration was denied.

ISSUE

Whether the Court of Appeals correctly dismissed Valencia’s appeal based on procedural grounds.

RULING

The Supreme Court denied the petition. The Court held that the dismissal by the Court of Appeals was proper due to Valencia’s failure to comply with mandatory procedural rules under Rule 42 of the Rules of Court. The procedural defects were not mere technicalities but requirements essential to the orderly administration of justice. Valencia did not correct these errors despite being notified. The bare invocation of “substantial justice” does not automatically suspend procedural rules. The findings of fact by the lower courts, which convicted Valencia based on credible circumstantial evidence proving all elements of adultery, are final and conclusive in a petition for review on certiorari under Rule 45, which is limited to questions of law.