A.M. No. RTJ-12-2325, A.M. OCA IPI No. 11-3649-RTJ - Office of the Court Administrator vs. Flores

Evelyn Barredo, the petitioner, was charged with perjury for allegedly making an untruthful statement in her affidavit-complaint.
The affidavit-complaint pertained to the alleged usurpation of police functions and illegal detention attributed to Atty. Ricardo D. Gonzalez.
The controversial statement accused the private complainant of ordering the police to impound her truck—loaded with sacks of rice—and to detain her truck helpers following a vehicular mishap on September 12, 1998.

The case was originally docketed in the Municipal Trial Court in Cities (MTCC), Butuan City, Criminal Case No. 24149.
Despite Barredo’s defense that the technical wording was prepared by her lawyer and executed in good faith, Branch 1 of the MTCC found her guilty of perjury.
The MTCC Judgment dated October 10, 2006 imposed an indefinite prison term ranging from two months of arresto mayor (minimum) to one year and eight months of prision correccional (maximum).
Additionally, Barredo was ordered to pay moral damages amounting to P100,000 to Atty. Ricardo D. Gonzales.

On appeal, Branch 3 of the Regional Trial Court (RTC) of Butuan City affirmed the trial court’s conviction on October 30, 2007.
Barredo’s petition for review was dismissed by the Court of Appeals, Cagayan de Oro City, on January 30, 2008, on a technical ground: her petition did not include a duplicate original or a true copy of the MTCC decision.
Barredo contended that her appellate petition should be reinstated because she had attached a carbon copy of the RTC decision, which contained verbatim the MTCC findings and extensive discussions on the application of the law.
A Manifestation by the People of the Philippines, filed by then Solicitor General Agnes VST Devanadera, argued that, for substantial justice, the petition should be reinstated and decided on its merits, stressing the standard of judicial review in cases affecting personal liberty.
The private complainant submitted a motion stating his intention to cease further action against Barredo in both the criminal and civil aspects, subject to her commitment not to pursue any suit in connection with the matter. However, his submission was deemed deficient as it failed to contain a proper prayer for relief and set necessary conditions.

The procedural issue revolved around Rule 42, Section 2(d) of the 1997 Rules of Civil Procedure, which requires that a petition be accompanied by clearly legible duplicate originals or true copies of the judgments or final orders from both lower courts.
The Court highlighted that the deficiency noted—the absence of the duplicate original of the MTCC decision—was immaterial because the RTC decision, which was properly attached, fully replicated the findings and discussions of the MTCC.
The Court emphasized that the purpose of the rules of procedure is to facilitate justice rather than to serve as a rigid mechanism that may forfeit life, liberty, honor, or property on mere technicalities.

Whether the failure to attach a duplicate original or true copy of the MTCC decision, as mandated by the 1997 Rules of Civil Procedure, rendered Barredo’s petition insufficient, thereby justifying its dismissal.
Whether the existing RTC decision attached to the petition, which comprehensively contained the findings and legal discussions of the MTCC, was adequate to meet the substantive requirements of the petition.

Whether strict application of procedural rules—in this case, the attachment of a duplicate MTCC decision—would frustrate the substantial justice due to the deprivation of an opportunity to review the merits of a criminal conviction involving personal liberty.
Whether the rule should be flexibly interpreted to avoid technicalities that may lead to grave injustice.