G.R. No. 253450 - Nayve-Pua vs. Union Bank of the Philippines

Petitioners Rosa Yap Paras and Valente Dy Yap initiated the action seeking to set aside two resolutions of the Court of Appeals (Fourteenth Division), dated June 23, 1999 and October 13, 1999.
The petition for certiorari in CA-G.R. SP No. 53059 was filed to challenge the dismissal of their petition regarding the inhibition of Judge Ismael O. Baldado of the Regional Trial Court, Branch 45, Bais City, who was handling Special Civil Case No. 97-025-BY.
The Special Civil Case pertained to the declaration of Justo J. Paras as the sole administrator of the conjugal properties of his marriage with petitioner Rosa Yap Paras, while an annulment case was pending.

Petitioners filed a motion to inhibit Judge Baldado on the ground that he was a former partner in the private law firm of one of the respondents, and because of his perceived bias as evidenced in the prior case Evangeline Dinapol vs. Judge Baldado.
The motion to inhibit was denied on January 15, 1999, and a subsequent motion for reconsideration was also denied on March 9, 1999, leading petitioners to file the petition for certiorari with the Court of Appeals.

The Court of Appeals dismissed the petition for certiorari based on the alleged failure to comply with Section 1, Rule 65 of the 1997 Rules of Civil Procedure, specifically the requirement to attach duplicate original or certified true copies of the impugned RTC order.
The CA resolution of June 23, 1999 held that the attached document was merely a plain xerox copy rather than a certified true copy, and cited Section 3, Rule 46, which mandates dismissal for non-compliance with the prescribed requirements.
Petitioners, asserting that they had attached duplicate original copies and later submitted certified true copies in a motion for reconsideration, argued that they had substantially complied with the procedural requirements.

Petitioners contended that the strict dismissal on a technicality deprived them of the opportunity to present the merits of their petition and adversely affected the administration of justice in Special Civil Case No. 97-025-BY.
They maintained that the procedural requirements, while mandatory, must be interpreted in a manner that does not foreclose the opportunity to adjudicate the substantive issues of the case.
The petitioner’s position was that the administrative lapse in certification should not preclude both their substantive claims and the proper administration of justice.

Private respondent Justo Paras argued that compliance with Section 1, Rule 65 is jurisdictional and mandatory, and that the petition was unmeritorious and intended solely to delay proceedings.
Respondents maintained that the CA was correct in dismissing the petition based on non-compliance with procedural requirements.

The case involved interpretation of Section 3, Rule 46 of the 1997 Rules of Civil Procedure regarding the requirement for certified true copies of the order or judgment subject of the petition.
The Rules of Court were also noted to be liberally construed, per Section 6, to promote a just, speedy, and inexpensive resolution of cases, ensuring that technicalities do not result in gross injustice.

Whether the dismissal of the petition for certiorari by the Court of Appeals, based on the failure to attach duplicate original or properly certified true copies of the RTC order, was proper and warranted under the applicable procedural rules.
Whether substantial compliance with the procedural requirements, evidenced by the attachment of duplicate originals and the subsequent submission of certified copies by the petitioner’s clerk of court, should excuse the initial technical lapse.
Whether the strict application of procedural technicalities would unduly deprive a litigant of the opportunity to present the merits of the case, thus violating the principles of due process and access to an impartial tribunal.