G.R. No. 158708 - Maniebo vs. Court of Appeals

On July 1, 1994, the petitioner, Justina Maniebo, was given a promotional permanent appointment as Cashier III in the Office of the Municipal Treasurer of Puerto Galera, Oriental Mindoro.
The appointment was based on qualifications including a Career Service (Professional) Eligibility, purportedly obtained by the petitioner with a rating of 74.01% on the July 17, 1983 examination.
Upon verification with the Masterlist of Eligibles, the Civil Service Commission (CSC) discovered the petitioner actually failed the examination with a rating of only 60%.

The CSC Regional Office (CSCRO) No. IV conducted a preliminary investigation and found a prima facie case of falsification against the petitioner.
On October 28, 1997, formal charges were filed against her for possession of spurious report of rating, falsification, grave misconduct, and dishonesty.
The petitioner filed an answer but it was deemed unsatisfactory; the case was set for hearing.

During the hearing, the petitioner denied knowledge of falsification and claimed she honestly received the report by mail.
On December 16, 1999, CSCRO found her guilty of the charged offenses and meted the penalty of dismissal from the service.

The petitioner appealed to the CSC on February 4, 2000.
The CSC, through Resolution No. 02-0433 dated March 20, 2002, affirmed the decision of CSCRO.
Her motion for reconsideration filed on August 20, 2002 was denied by CSC via Resolution No. 02-1028.

The petitioner submitted several annexes (CSC resolutions, notices, affidavits).
On September 5, 2002, the CA dismissed the petition for review due to failure to attach certified true copies of material portions of the record as required under Section 7, Rule 43 of the Rules of Court.
The petitioner’s motion for reconsideration, filed on October 23, 2002 with a promise to submit certified copies, was denied by the CA on January 8, 2003 because of failure to comply and procedural deficiencies (lack of allegation on date of receipt of resolution).
A second motion for reconsideration filed on February 5, 2003 was denied by the CA as prohibited under Rule 52, Sec. 2 of the Rules of Court.

The petitioner filed a petition for review on certiorari seeking reversal of the CA rulings and reinstatement of her appeal.

Whether the Court of Appeals erred in dismissing the petition for review due to failure to attach certified true copies of all annexes when jurisprudence allegedly does not require certification of all annexes.
Whether the Court of Appeals committed reversible error in dismissing the petition based on a technicality not sanctioned by jurisprudence.