G.R. No. 257446 - Jhon Kenneth M. Porto, Chennie Ann Rose Elca, and Jomar Jonhedel B. Bruto vs. Grant Institute of Trade and Technology, Inc.

Petitioners: Jhon Kenneth M. Porto, Chennie Ann Rose Elca, and Jomar Jonhedel B. Bruto (represented by Marife B. Bruto).
Respondents: Grant Institute of Trade & Technology, Inc. (GITT) and its Board of Directors (Dr. Ruel Reyes, Atty. Janet Joy A. Reyes, Lisha Alyanna A. Reyes, Jesse R. Reyes, and Nestor R. Miranda).
Subject Matter: Petitioners challenged the Resolutions of the Court of Appeals (CA) dismissing their Joint Petitions for Certiorari that sought to assail earlier resolutions by the Office of the City Prosecutor (OCP) and the Office of the Regional Prosecutor (ORP) concerning criminal indictments for estafa.

Seven complainants, including petitioners, enrolled in the Cruise Ship Management Course offered by GITT.
The course was allegedly provided under the pretense that GITT had the requisite authority and licenses from the Technical Education & Skills Development Authority (TESDA).

Complaints surfaced when petitioners and the other complainants confirmed with TESDA Laguna Provincial Office that GITT did not have the authority to offer the course.
Private respondents submitted a counter-affidavit asserting that the complaints were baseless and that the institution acted in good faith.

On September 30, 2019, the OCP-San Pablo City issued a Resolution recommending the filing of Information for estafa against the private respondents.
The Resolution rested on evidence of GITT’s misrepresentation regarding its TESDA accreditation and licensure, despite claims of good faith.

Private respondents later filed a petition before the ORP-Region IV, which reversed and set aside the OCP’s Resolution on January 20, 2020.
The ORP emphasized the need for clear and convincing evidence that the board members were aware of the lack of TESDA authority, noting that GITT had in fact applied for such authority and that complainants never presented proof of tuition fee payment.

Petitioners elevated the case to the CA through Joint Petitions for Certiorari, asserting that the ORP’s reversal involved grave abuse of discretion.
The CA issued a Resolution dated November 20, 2020 dismissing the Joint Petitions on multiple procedural grounds.

Failure to pay the requisite docket fee at filing time.
Deficiency in submitting the required sworn verification and certification against forum-shopping.
Inadequate provision of actual, current, and complete addresses of the petitioners.
Failure to furnish copies of the Joint Petitions to ORP-Region IV.
Lack of proper signature on the petition documents in accordance with the Rules of Court.

Petitioners filed a Joint Motion for Reconsideration with pleas for procedural leniency, citing difficulties due to the COVID-19 pandemic and other mitigating factors.
The CA, in its Resolution dated June 14, 2021, denied the motion for reconsideration, affirming the dismissal based on both procedural lapses and the additional ground of non-exhaustion of the DOJ-NPS appellate process.

The CA argued that petitioners failed to appeal the ORP’s Resolution through the Secretary of Justice as required by DOJ Department Circular No. 70 (the 2000 NPS Rule on Appeal).
Petitioners contended that an amendment, DOJ Department Circular No. 70-A, delegated authority to Regional State Prosecutors, therefore obviating the need to directly appeal to the Secretary of Justice.

Several DOJ Department Circulars (including Nos. 18, 3, 3-A, 34, and 27) were cited concerning the proper appellate process in cases involving preliminary investigations and resolutions of the prosecution.
The evolution of these rules and circulars played a role in the interpretative dispute regarding the exhaustion of administrative remedies.

Whether the CA erred in dismissing the Joint Petitions for Certiorari on the basis of multiple procedural deficiencies (non-payment of docket fees, absence of complete addresses, missing verification and certification, and unsigned petitions).
Whether invoking strict procedural requirements was justified even in light of petitioners’ argument for a liberal application of the Rules of Court due to the COVID-19 pandemic and other mitigating circumstances.

Whether the CA erred in requiring petitioners to exhaust the DOJ-NPS appellate process by appealing the ORP’s Resolution to the Secretary of Justice, despite the existence and purported effect of DOJ Department Circular No. 70-A.
Whether the dismissal on this ground was appropriate given that the underlying administrative process had been governed by evolving DOJ circulars which delegated appellate authority.