CASE DIGEST : JESUS CABALLES v. CA GR No. 263481, Feb 08, 2023 GAERLAN

 FACTS : The case arose from an agrarian dispute where the Regional Agrarian Reform Adjudicator (RARAD) ruled in favor of petitioner Jesus Caballes, but the Department of Agrarian Reform Adjudication Board (DARAB) reversed the decision. After the DARAB denied his motion for reconsideration, petitioner received the resolution on February 11, 2021 and filed a petition for review under Rule 43 of the Rules of Court before the Court of Appeals (CA) on February 26, 2021. However, the CA dismissed the petition under Sections 4, 6, and 7 of Rule 43, citing six procedural defects: alleged late filing, submission of plain photocopies of the assailed DARAB rulings, failure to state material dates, defective verification for lack of competent proof of identity under the 2004 Rules on Notarial Practice, an outdated IBP receipt in violation of Bar Matter No. 287, and failure to indicate the respondents’ addresses.

Petitioner filed a Motion for Reconsideration with an Amended Petition for Review, curing all the cited procedural defects. Nevertheless, the CA denied the motion, maintaining that the petition was filed three days beyond the reglementary period and refusing to consider the corrected deficiencies. Consequently, petitioner filed a Petition for Certiorari under Rule 65, alleging that the CA committed grave abuse of discretion in dismissing his appeal despite its timely filing and despite his compliance with the procedural requirements. In opposition, private respondents argued that certiorari was the wrong remedy, that the CA correctly dismissed the petition because of multiple procedural defects, and that the DARAB Decision had already become final and executory.

ISSUE : WON CA is correct

HELD : The Supreme Court held that the Court of Appeals (CA) committed grave abuse of discretion in dismissing Caballes’ Rule 43 petition for review on procedural grounds. Under Rule 65, grave abuse of discretion exists when there is a capricious, whimsical, or arbitrary exercise of judgment amounting to an evasion of a positive duty. The Court found that the CA erroneously ruled that the petition was filed three days late despite Section 3, Rule 13 of the Rules of Court, which expressly provides that the date of mailing, as evidenced by the registry receipt or post office stamp, is deemed the date of filing. Since Caballes mailed his petition on February 26, 2021, the last day of the 15-day reglementary period under Sections 4 and 6, Rule 43, the petition was timely filed. The CA further aggravated its error by refusing to correct its mistake even after Caballes attached the registry receipts to his motion for reconsideration.

The Court likewise ruled that the remaining procedural defects did not justify the outright dismissal of the petition because Caballes substantially complied with the Rules. His failure to state the dates of receipt of the DARAB decision and the filing of his motion for reconsideration was not fatal since, under Section 6(d), Rule 43 and Victoriano v. Dominguez, the material date is the receipt of the resolution denying the motion for reconsideration, which he properly alleged. His subsequent submission of certified true copies of the DARAB decision and resolution with his motion for reconsideration constituted substantial compliance with Section 6(c), Rule 43, consistent with Duremdes v. Jorilla. The Court also held that neither Section 12, Rule II of the 2004 Rules on Notarial Practice nor Rule 43 requires attaching a photocopy of the affiant’s identification card to the petition, citing Heirs of Amada Zaulda v. Zaulda. Similarly, counsel’s outdated IBP receipt number and the omission of respondents’ personal addresses were later corrected through the amended petition and caused no prejudice to the adverse parties, following the rulings in Go v. Sunbanun and Victoriano v. Dominguez.

Emphasizing that procedural rules are designed to promote—not defeat—substantial justice, the Court reiterated that litigation is not a game of technicalities and that rigid adherence to procedural rules must yield when substantial compliance is shown and no prejudice is caused to the opposing party. Accordingly, the Supreme Court granted the petition, reversed and set aside the CA’s Minute Resolution and Resolution, and remanded the case to the Court of Appeals for resolution of Caballes’ petition for review on the merits.