CASE DIGEST : JOVEN AND GARCIA VS SPOUSES TULIO GR 204567 GAERLAN

[ G.R. No. 204567, August 04, 2021 ]

EMILIANO D. JOVEN, AND CICERO V. GARCIA PETITIONERS, VS. SPOUSES RAUL L. TULIO AND CRISTINA PANGANIBAN TULIO, RESPONDENTS.

FACTS : At the core of this dispute is a commercial property in San Fernando, Pampanga, owned by Sps. Raul L. Tulio and Cristina Panganiban Tulio, and leased to petitioners Emiliano D. Joven and Cicero V. Garcia from November 1, 1999 to October 31, 2013, during which the petitioners constructed a two-storey mall at their own expense. Disputes arose over unpaid rentals and alleged forcible entry when respondents reassumed possession on June 3, 2000, prompting the petitioners to file a forcible entry complaint. The MTCC ruled in favor of respondents’ lawful possession but ordered reimbursement of advance rentals and half the cost of improvements. The RTC issued conflicting rulings: first, denying reimbursement for improvements and reducing advance rental refunds; later, upon reconsideration, it ruled respondents committed forcible entry and ordered repayment for improvements and rentals; finally, a subsequent RTC modification reverted the decision, recognizing respondents’ lawful possession and limiting refunds to P250,000. Petitioners then filed a Rule 42 Petition for Review with the CA, which dismissed it on technical grounds, citing defective notarization, verification, and lack of attached RTC/MTCC records. The petitioners’ motion for reconsideration was denied, leading to the present recourse.

ISSUE : WON the CA erred in dismissing outright petitioners' Rule 42 Petition for Review

HELD : In this case, the Supreme Court emphasized that procedural technicalities should facilitate, not obstruct, justice. While the CA dismissed petitioners’ Rule 42 petition due to alleged defects in notarization, verification, certification against forum shopping, and failure to attach documents, the Court found that these deficiencies were not fatal. Verification and certification were deemed substantially compliant because petitioners shared a common interest, and the notarization defects were cured after submission of the notary’s commission. The failure to attach all pleadings was insufficient for outright dismissal, as only relevant documents are required, and the material allegations were already summarized in prior rulings. Guided by the principle that cases should be resolved on their merits rather than technicalities, the Court granted the petition, reversed and set aside the CA Resolutions, and reinstated the case, instructing the CA to proceed with due deliberation to decide the matter on the merits.