Case Digest (G.R. No. 263481)
Facts:
Petitioner Jesus Caballes filed a complaint before the Regional Agrarian Reform Adjudicator (RARAD) of Tagum City against private respondents Corazon Adolfo Calderon et al., and the RARAD ruled for petitioner. The Department of Agrarian Reform Adjudication Board (DARAB) reversed in a Decision dated December 26, 2019 and denied petitioner’s motion for reconsideration in a Resolution dated December 14, 2020; petitioner received the DARAB resolution on February 11, 2021 and mailed a petition for review under Rule 43 to the Court of Appeals on February 26, 2021, but the CA dismissed the petition on procedural grounds and denied reconsideration, prompting this Rule 65 petition.
Issues:
- Whether the Court of Appeals committed *grave abuse of discretion* in ruling that petitioner’s petition for review was belatedly filed.
- Whether the CA erred in dismissing the petition for failure to attach certified true copies of the assailed Decision and Resolution.
- Whether the CA erred in dismissing the petition for failure to state the dates of receipt of the Decision and filing of the motion for reconsideration.
- Whether the CA erred in dismissing for failure to show competent evidence of identity by not attaching a photocopy of petitioner’s ID.
- Whether the CA erred in dismissing for an outdated IBP official receipt number of counsel.
- Whether the CA erred in dismissing for omission of respondents’ addresses.
- Whether the CA committed grave abuse in denying the motion for reconsideration after the lapse of more than a year.
Ruling:
The petition was granted. The Court held that the CA committed grave abuse of discretion in ruling the petition belated, reversed and set aside the Minute Resolution dated March 25, 2021 and the Resolution dated June 24, 2022, and remanded the case to the CA for resolution on the merits. The Court further ruled that the other procedural defects did not justify outright dismissal given petitioner’s timely filing and his subsequent correction by an amended petition attached to his motion for reconsideration.
Ratio:
The Court found that grave abuse of discretion requires a patent and gross misuse of power and was shown by the CA’s disregard of Sec. 3, Rule 13, Rules of Court, which treats the post office registry receipt date as the filing date; petitioner mailed the petition on February 26, 2021 as shown by registry receipts. The Court applied the doctrine of substantial compliance and prior precedents such as Victoriano v. Dominguez, Duremdes v. Jorilla, Heirs of Amada Zaulda v. Zaulda, and Go v. Sunbanun to hold that failures to attach certified copies, to state certain material dates, to attach a photocopy of the ID, to show an updated IBP receipt number, or to state respondents’ addresses were not fatal where defects were promptly cured and no prejudice resulted.
Doctrine:
- *Grave abuse of discretion* denotes a patent and gross exercise of power and is the proper ground for relief under Rule 65.
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