G.R. No. 263481 - Caballes vs. Court of Appeals

Petitioner Jesus Caballes initiated a complaint against eight private respondents before the Regional Agrarian Reform Adjudicator (RARAD) in Tagum City, where the RARAD ruled in his favor.
The private respondents, a family group and an associate, subsequently had their action appeal the favorable RARAD decision by filing before the Department of Agrarian Reform Adjudication Board (DARAB), which in Decision dated December 26, 2019 reversed the RARAD ruling.
Petitioner’s subsequent motion for reconsideration of the DARAB resolution was denied on December 14, 2020.

Petitioner received a copy of the DARAB resolution on February 11, 2021, and then filed his petition for review via registered mail on February 26, 2021, claiming compliance with the rules by demonstrating the filing date through registry receipts.
The Court of Appeals (CA), in a Minute Resolution dated March 25, 2021, and later in a Resolution dated June 24, 2022, dismissed petitioner’s petition for review for a series of alleged procedural defects, which included:

Alleged late filing of the petition (filing three days beyond the prescribed reglementary period).
Submission of plain photocopies instead of duplicate originals or certified true copies of the assailed DARAB Decision and Resolution.
Failure to indicate the dates of receipt of the decision and the filing of the motion for reconsideration.
Failure to attach a photocopy of the petitioner’s valid identification card as competent evidence of identity.
Use of an outdated Integrated Bar of the Philippines (IBP) official receipt number by petitioner’s counsel.
Omission of the addresses of the private respondents.

In response, petitioner filed a Motion for Reconsideration with an Attached Amended Petition for Review on April 27, 2021, correcting the noted defects.
Despite these remedial efforts, the CA maintained its dismissal, basing its decision chiefly on the alleged belated filing of the petition.
Concurrently, without awaiting the resolution of the petition, private respondents filed a Comment/Opposition to the Petition for Certiorari, contending that:

Petitioner availed the wrong remedy by filing a petition for certiorari instead of addressing the procedural defects appropriately.
The CA’s dismissal was proper given the compounded six procedural defects.
The DARAB decision had thus become final and executory.

Petitioner submitted registry receipts as evidence to prove that the petition was mailed on February 26, 2021—the last day of the 15-day reglementary period provided under the Rules of Court.
Petitioner’s amended motion for reconsideration also contained corrected documents addressing the defects regarding the photocopies, the posting of material dates, the proper certification of identification, the updated IBP official receipt, and the inclusion of respondents’ addresses.
The CA, however, relied on its original determination regarding the supposedly belated filing and rigidly applied technical requirements without considering the substantial compliance evidenced by petitioner’s corrective efforts.

Whether the CA committed grave abuse of discretion amounting to lack or excess of jurisdiction by ruling that petitioner’s petition for review was belatedly filed.
Whether the CA committed grave abuse of discretion by dismissing the petition for review for failure to attach certified true copies of the assailed decisions.
Whether the CA committed grave abuse of discretion by dismissing the petition for review due to failure to indicate the date of receipt of the assailed decision and the filing of the motion for reconsideration.
Whether the CA committed grave abuse of discretion in dismissing the petition for failure to show competent evidence of identity by attaching a photocopy of the voter’s ID.
Whether the CA committed grave abuse of discretion by dismissing the petition for indicating an outdated IBP official receipt number of petitioner’s counsel.
Whether the CA committed grave abuse of discretion by dismissing the petition for failure to state the addresses of the private respondents.
Whether the CA committed grave abuse of discretion for denying petitioner’s motion for reconsideration (with the attached amended petition for review) after nearly a year.