Case Summary (G.R. No. 43556)
Factual Background
The dispute arose from a boundary contention between Ormoc City and the Municipality of Kananga, which was resolved through an Amicable Settlement dated February 27, 2003. This settlement, which modified Ormoc City’s territory by 325 hectares, was later contested by the petitioner, claiming it constituted an unlawful relinquishment of its patrimony. The petitioner sought to annul both the Amicable Settlement and the order that approved it via a petition filed before the Court of Appeals (CA), Cebu City.
Procedural History
Initially, the CA dismissed the petition due to procedural defects, but upon the petitioner’s motion for reconsideration, it reinstated the case after the petitioner corrected these defects. Notably, only respondents Municipality of Kananga and PNOC-EDC filed answers, while Ormoc City supported the petitioner.
Petitioner’s amended petition was dismissed by the CA in its November 24, 2011 resolution, primarily due to failures in documentation, including the absence of a proper Barangay Council Resolution authorizing Isagani R. BaAez to sign critical documents.
Issues Raised
The core issues revolved around the petitioner’s alleged procedural infirmities and whether these warranted dismissal of the amended petition. The CA raised concerns over the certification against non-forum shopping lacking the necessary proof of identity and being sworn before an alleged unauthorized official. Petitioner later attempted to cure these defects by submitting a new Barangay Resolution and Verification.
Ruling of the Court
The Supreme Court found merit in the petitioner’s arguments, observing that strict procedural compliance should not overshadow the pursuit of substantive justice. It acknowledged that while the original authority for signing the Certification against Non-forum Shopping was lacking, the belated submission of the Barangay Council Resolution, alongside the amended Verification, constituted substantial compliance with procedural requirements.
The Court emphasized that adherence to procedural rules should not lead to injustice, especially given that the
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Background and Antecedents of the Case
- The case revolves around a boundary dispute between Ormoc City and the Municipality of Kananga.
- On February 27, 2003, both local government units entered into an Amicable Settlement to resolve the boundary issue, which was subsequently approved by the Regional Trial Court.
- The petitioner, Barangay Tongonan, represented by its Punong Barangay Isagani R. BaAez, contended that the Amicable Settlement was an illegal relinquishment of Ormoc City's patrimony, significantly altering its boundaries and reducing its territory by 325 hectares.
- In response to this perceived injustice, the petitioner filed a petition before the Court of Appeals (CA), Cebu City, seeking to annul the Amicable Settlement and the court's order approving it.
Procedural History
- The initial petition was dismissed by the CA Cebu City due to procedural defects noted in its Resolution dated June 18, 2010.
- Following a motion for reconsideration, the CA reinstated the petition as the petitioner corrected the procedural infirmities and directed the issuance of summons to the respondents.
- Notably, only the Municipality of Kananga and PNOC-EDC filed answers, while Ormoc City supported the petitioner’s position.
Dismissal of the Amended Petition
- On November 24, 2011, the CA dismissed the amended petition for the following reasons:
- The pet