G.R. No. 151037 - San Miguel Corporation vs. Monasterio

Rosario Vda. de Pelaez filed a complaint for prohibition under Section 27 of the Agricultural Tenancy Act (R.A. No. 1199) on November 12, 1992, before the Department of Agrarian Reform Adjudication Board, alleging that she was instituted as a tenant on a parcel of coconut land originally owned by the late Rosenda Reyes y Padua.
The land, covered by TCT No. T-79099 and measuring 3.0896 hectares, is situated in Barangay Mangilag Norte, Candelaria, Quezon.
Respondent (Rosario) claimed that the tenancy was established by the late Rosenda, who had originally placed her and her husband as tenants when the land was held prior to its sale.

In 1978, petitioner Cesar Jaro purchased the land from Ricardo Padua Reyes, the heir of Rosenda Reyes y Padua.
Petitioner contended that Rosario was never a tenant since she neither shared in the harvests nor received any form of payment for her work, noting that he had allowed her to remain on the property based on an understanding that her house could be removed at his discretion.
The factual dispute centers on whether Rosario was a bona fide tenant or merely an occupant by the gracious disposition of the landowner.

On October 6, 1993, the Provincial Adjudicator rendered a decision in favor of petitioner, holding that conflicting affidavits (including one from Ricardo in May 1978 and another in November 1992) demonstrated that Rosario was not tenant but rather a mere occupant.
Dissenting from the Provincial Adjudicator’s decision, the Department of Agrarian Reform Adjudication Board (DARAB) in its April 22, 1996 decision reversed the ruling by giving greater weight to the November 1992 affidavit, thus declaring Rosario’s status as that of a tenant with security of tenure.
Petitioner subsequently filed a Motion to Dismiss the appeal of the respondent before DARAB, and when that motion was not successful, he pursued further administrative remedies.

Petitioner filed an appeal on certiorari with the Court of Appeals against the DARAB decision, challenging the dismissal of his petition based on alleged procedural non-compliance with Supreme Court Revised Administrative Circular No. 1-95 and Administrative Circular No. 3-96.
On October 23, 1996, the Court of Appeals dismissed the appeal outright on two main technical bases:

The appeal was not in the form of a petition for review as required by the Supreme Court Administrative Circular No. 1-95.
The annexes accompanying the petition were only certified as true xerox copies by petitioner’s counsel, rather than being certified true copies or duplicate originals as mandated.

Despite petitioner’s subsequent filing of an amended petition (with the correct supporting documents) and several motions for reconsideration (filed on November 8, 1996, and December 13, 1996), the Court of Appeals dismissed these filings, reiterating that the non-compliance was attributable to petitioner and that no highly justifiable and compelling reasons had been presented to overcome the strict requirements.

Is petitioner entitled to annul the impugned decisions and resolutions of both the DARAB and the Court of Appeals based on the technical defects noted in the filing of his petition and the subsequent dismissal on procedural grounds?

Does the subsequent and substantial compliance in filing the amended petition and supporting documents justify a relaxation of the rigid procedural requirements?
Should technical non-compliances—such as the lack of certified true copies or duplicate originals—override the opportunity for a full, merit-based adjudication of the case?
Was the dismissal of the appeal by the Court of Appeals, on the basis of strict adherence to the rules, an evasion of the substantive justice owed to the petitioner?