Facts:

The case involves Barangay Tongonan, Ormoc City, represented by its Punong Barangay, Isagani R. BaAez, as the petitioner against Hon. Apolinario M. Buaya, in his capacity as Presiding Judge of the Regional Trial Court, Branch 35, Ormoc City, along with the City Government of Ormoc, represented by Mayor Eric C. Codilla, the Municipality of Kananga, Leyte, represented by Mayor Giovanni M. Napari, and the Philippine National Oil Company - Energy Development Corporation (PNOC-EDC), represented by its President, Mr. Paul Aquino, as respondents. The dispute arose from a boundary conflict between Ormoc City and the Municipality of Kananga, which led to an Amicable Settlement dated February 27, 2003. This settlement was later approved by the court, but the petitioner claimed it illegally relinquished Ormoc City's patrimony, altering its boundaries and reducing its territory by 325 hectares. Consequently, the petitioner filed a petition with the Court of Appeals (CA) in Cebu City ...

Facts:

1. Boundary Dispute and Amicable Settlement: The case arose from a boundary dispute between Ormoc City and the Municipality of Kananga. To resolve the dispute, the parties entered into an Amicable Settlement on February 27, 2003, which was later approved by the Regional Trial Court (RTC).
2. Petitioner's Claim: Barangay Tongonan, represented by its Punong Barangay, Isagani R. Bañez, filed a petition before the Court of Appeals (CA) seeking to annul the Amicable Settlement. The petitioner argued that the settlement illegally reduced Ormoc City's territory by 325 hectares, affecting Barangay Tongonan's boundaries.
3. Procedural Defects: The CA initially dismissed the petition due to procedural defects, including the failure to submit the original Barangay Council Resolution authorizing the Punong Barangay to sign the Verification and Certification Against Non-Forum Shopping. The CA also noted issues with the identity of the affiant and the subscription of the certification before an Assistant Provincial Prosecutor.
4. Rectification Attempts: Petitioner attempted to rectify the defects by submitting a new Barangay Council Resolution and a new Verification and Certification Against Non-Forum Shopping, executed by the new Punong Barangay, Periander R. Bañez. However, the CA denied the motion for reconsideration, leading to the filing of the instant petition before the Supreme Court.

Issue:

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Ruling:

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Ratio:

1. Substantial Compliance: The Court emphasized that strict compliance with procedural rules may be relaxed in the interest of justice, especially when there is substantial compliance. The belated submission of the required documents cured the procedural defects.
2. Jurisprudence on Procedural Defects: The Court cited several cases (e.g., Mediserv, Inc. v. Court of Appeals, Uy v. Land Bank of the Philippines, and Havtor Management Phils. Inc. v. NLRC) where belated submissions were allowed to cure procedural defects, provided there was substantial compliance.
3. Importance of Substantive Justice: The Court highlighted that procedural rules should not be interpreted with absolute literalness to the detriment of substantive justice. The resolution of the boundary dispute, which involves public interest, should take precedence over procedural technicalities.
4. Authority of Representatives: The Court noted that the change in Barangay leadership necessitated the submission of a new Barangay Council Resolution authorizing the new Punong Barangay to sign the certification. This did not invalidate the petition, as the new resolution sufficiently authorized the representative.

Conclusion:

The Supreme Court granted the petition, reversed the CA's Resolutions, and remanded the case to the CA for proper disposition. The Court emphasized the importance of substantial compliance with procedural rules and the need to prioritize substantive justice over technicalities.