G.R. No. 139607 - Sps. Lapid vs. Laurea

Petitioners Ramon Isidro P. Lapid and Gladys B. Lapid, acting on behalf of their seven‐year‐old son, Christopher B. Lapid, a Grade 1 pupil at St. Therese of the Child Jesus, Inc. in Malabon, Metro Manila.
Respondents include the presiding judge of the RTC, Branch 169, Malabon (Hon. Emmanuel D. Laurea), and the school officials of St. Therese of the Child Jesus, Inc. (directress Mrs. Esperanza N. Prim, teacher-in-charge Ms. Norilyn A. Cruz, guidance counselor Mrs. Flordeliza C. Santos, and principal Mr. Macario B. Binondo), as well as parties representing the Court of Appeals.

On November 5, 1997, Mrs. Gladys Lapid visited the school seeking to speak with the classroom teacher, Ms. Norilyn A. Cruz. She was disallowed by the directress who cited disruption of ongoing classes and advised her to return later on the same day.
Upon her return, Mrs. Lapid learned from a letter prepared by the school principal that her son Christopher had been suspended for five days effective the following day, effectively dismissing him from class without the benefit of notice or a hearing.
Petitioners asserted that they had no knowledge of any prior letters of complaint, particularly those alleging offenses committed by Christopher, and maintained that the suspension was arbitrary and damaging to their son’s reputation.
The strained relationship between the petitioners and the school administration led to the immediate transfer of Christopher to another school.
Petitioners further escalated the matter by filing a letter-complaint with the Undersecretary of the Department of Education, Culture & Sports (DECS), demanding an investigation and a public retraction/apology from the school officials. The school, however, refused to comply, prompting petitioners to seek redress through legal action for damages.

Initially, petitioners filed a complaint for damages in the RTC, Malabon, Branch 169, docketed as Civil Case No. 2839 MN, alleging that the school’s actions had tarnished the good name and reputation of their family and sought moral, exemplary, and consequential damages.
On November 18, 1998, petitioners filed a motion to declare the school in default, which was denied by the RTC on February 9, 1999.
Petitioners then brought a petition for certiorari before the Court of Appeals, filed under CA-G.R. SP No. 52970.

In its first resolution dated June 1, 1999, the Court of Appeals dismissed the petition on the ground that petitioners failed to indicate a material date – specifically the date the motion for reconsideration was filed with the RTC – as required by Supreme Court Circular No. 39-98 and Section 3 of Rule 46 of the 1997 Rules of Civil Procedure.
Petitioners then sought reconsideration by filing a motion on June 15, 1999; however, the Court of Appeals denied this motion as well in its subsequent resolution dated August 4, 1999.

Petitioners argued before the Supreme Court that dismissing the petition on mere technicality overlooked the substantive merits of the case, even raising the issue of whether a corporation can act without its Board of Directors’ express concurrence.
Respondents contended that petitioners’ repeated non-compliance with the procedural requirements, particularly their failure to state necessary material dates accurately, warranted the dismissal.

Whether the Court of Appeals erred in dismissing the petition for certiorari solely on the ground of a procedural defect – namely, the failure of petitioners to state a material date (the date of filing the motion for reconsideration) as required by Rule 65 of the Rules of Court.
Whether such technical non-compliance could be excused by the purported substantive merits of the case, including the raised issue on corporate acts without the express concurrence of a board of directors.
Whether petitioners’ arguments invoking a liberal construction of procedural rules, due to the involvement of the minor and potential injustice, may justify setting aside the strict requirements of Rule 65.