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ISIDORO A. PADILLA v. LUIS ALIPIO

FACTS:

The case involves a petition for review filed by Isidoro A. Padilla, Jr., Clara Rita A. Padilla, and Joseph Haldos against spouses Luis and Milagros Alipio, after the Metropolitan Trial Court (MeTC) of Quezon City dismissed their action for ejectment. The plaintiffs claimed to be lawful possessors of a property in Quezon City, while the defendants argued that the plaintiffs were defendants in a previous ejectment case and had no right to possession. The MeTC ruled in favor of the defendants, and the decision was affirmed by the Regional Trial Court (RTC). The petitioners then filed a petition for review with the Court of Appeals, but it was dismissed for not being accompanied by true copies of the pleadings and other material portions of the record. The petitioners moved for reconsideration but were denied. The petitioners filed a petition for review on certiorari with the Supreme Court, arguing that there was substantial compliance with the procedural rules. The Supreme Court ruled in favor of the petitioners, stating that there was substantial compliance with the required attachments and that the Court of Appeals erred in dismissing the case. The Supreme Court remanded the case to the Court of Appeals for decision on the merits.

ISSUES:

  1. Whether or not the petition for review filed by the petitioners was properly dismissed by the Court of Appeals.

  2. Whether or not there was substantial compliance with the requirements of Section 2, Rule 42 of the 1997 Rules of Civil Procedure.

RULING:

  1. Yes, the Court of Appeals properly dismissed the petition for review filed by the petitioners. However, the dismissal was based on a procedural ground, which was the failure to submit true copies of the pleadings and other material portions of the record as required by Section 2, Rule 42 of the 1997 Rules of Civil Procedure. The Court ruled that the petitioners failed to attach a certified true copy of the Municipal Trial Court (MTC) decision, but this was not enough to warrant dismissal of the petition as the Court of Appeals was supposed to review the Regional Trial Court (RTC) decision, a certified true copy of which was attached to the petition. The decision of the RTC affirmed in toto the decision of the MTC, which had been quoted almost verbatim in the RTC decision.

  2. Yes, there was substantial compliance with the requirements of Section 2, Rule 42 of the 1997 Rules of Civil Procedure. The petition for review filed by the petitioners contained material portions of the pleadings and other relevant portions of the record, even though they were not certified true copies. The Court ruled that supporting documents to the petition are not required to be certified true copies, as long as the assailed judgment, order, or resolution is a certified true copy. The petitioners also submitted the relevant or pertinent documents along with their motion for reconsideration, which the Court considered a substantial compliance with the requirement. The Court emphasized that cases should be decided on the merits rather than on technicalities, and parties should be given ample opportunity for the proper disposition of their cause.

PRINCIPLES:

  • Failure to attach a certified true copy of the lower court's decision does not necessarily warrant dismissal of the petition for review. The Court of Appeals is supposed to review the higher court's decision, and as long as a certified true copy of that decision is attached to the petition, the failure to attach the lower court's decision does not affect the sufficiency of the petition. (Silverio v. Court of Appeals)

  • Supporting documents to a petition for review are not required to be certified true copies, as long as the assailed judgment, order, or resolution is a certified true copy. Submission of relevant or pertinent documents along with a motion for reconsideration constitutes substantial compliance with the requirement. The right to appeal is an essential part of the judicial system, and courts should proceed with caution to ensure that every party-litigant has ample opportunity for the proper disposition of their cause. (Cusi-Hernandez v. Diaz; Serrano v. Galant Maritime Services, Inc.)