Case Summary (G.R. No. 199107)
Factual Background and Procedural History
Larrazabal Enterprises owned three parcels in Ormoc City later compulsorily acquired under P.D. 27/E.O. 228, with emancipation patents issued to farmer-beneficiaries including petitioners. In 1999 Larrazabal Enterprises sued for recovery before the Regional Adjudicator, alleging no just compensation had been fixed or paid. The Regional Adjudicator ruled for Larrazabal, but on appeal DARAB reversed (barred by prescription/laches; Landbank certificates proved payment) before granting reconsideration and reinstating Larrazabal’s relief for lack of due process. Petitioners then filed a Rule 43 petition for review with the Court of Appeals.
Dismissal by the Court of Appeals for Formal Defects
The Court of Appeals summarily dismissed petitioners’ Rule 43 petition, citing: (1) inconsistent listing of party Raymundo Claros Codilla between motions; (2) failure in the verification/certification of non-forum shopping to show competent evidence of identity; (3) non-attachment of Larrazabal Enterprises’ original DARAB complaint; and (4) omission of the place of issue of counsel’s IBP annual dues receipt. A subsequent motion for reconsideration was likewise denied.
Doctrine of Liberal Construction of Procedural Rules
Under the 1987 Constitution’s due process guarantee and Rule 1, Section 6 of the Rules of Court, procedural rules must be liberally construed to secure just, speedy, and inexpensive disposition of cases. While compliance with formal requisites is generally mandatory, the Supreme Court has held that rules should not “straightjacket” justice (Obut v. Court of Appeals) and may be relaxed when strict adherence would defeat substantial rights. Courts should give litigants full opportunity to ventilate claims and avoid denying relief on mere technicalities absent compelling reasons.
Defects in Verification and Certification of Non-Forum Shopping
Rule 7, Sections 4 and 5 require pleadings to be verified by affidavit and accompanied by a certification against forum shopping. Jurisprudence distinguishes: verification defects are formal and curable (court may order compliance or dispense with it to serve justice); certification defects are generally uncurable but may be overlooked under special or compelling circumstances (Altres v. Empleo). Signature by a subset of parties with common interest suffices (Torres; Cavile; Olarte). Here, petitioners shared a unified interest in the agrarian titles and any omission of Codilla or identification documents should have been corrected rather than bar the appeal.
Relevance of Record Attachments in Rule 43 Petitions
Rule 43, Section 6 requires a copy of the appealed resolution and “material portions of the record … and other supporting papers.” Neither the original complaint nor every pleading must be appended—only those relevant to make out a prima facie case of grave abuse (Air Philippines). If a petitioner omits a pertinent document, the proper remedy is to allow its submission, not outright dismissal (Quintano; Panaga; Valenzuela).
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Facts of the Case
- Private respondent Larrazabal Enterprises owned three parcels of land in Sitio Coob, Barangay Libertad, Ormoc City: Lot Nos. 5383-G (7.6950 ha., TCT No. 10530), 5383-N (5.7719 ha., TCT No. 10530) and 5383-F (8.7466 ha., TCT No. 16178).
- In 1988, under Presidential Decree No. 27 (as amended by E.O. No. 228), the parcels were compulsorily acquired and Emancipation Patents with new titles were issued to farmer-beneficiaries, including the petitioners.
- In 1999, Larrazabal Enterprises filed an Action for Recovery before the Regional Adjudicator of the Department of Agrarian Reform Adjudication Board (DARAB), alleging non-payment of just compensation and praying for reconveyance of the lots.
- Petitioners answered, presenting Land Bank deposit certifications showing payments of ₱80,359.37 and ₱95,691.49 in Larrazabal Enterprises’ name, and asserting the validity of title cancellations, subdivisions and Emancipation Patents.
Procedural History
- October 15, 1999: Regional Adjudicator Diloy found no proof of compensation, ruled for Larrazabal Enterprises and ordered restoration of titles.
- September 16, 2008: DARAB reversed, holding Larrazabal’s action barred by prescription and laches and crediting Landbank certifications.
- September 30, 2009: On Larrazabal’s motion for reconsideration, DARAB reversed its decision, annulled Emancipation Patents for denial of due process.
- Petitioners sought a Rule 43 petition for review in the Court of Appeals (CA) under G.R. No. CA-AG.R. SP No. 04659.
- September 30, 2010: CA dismissed the petition for formal defects—name inconsistencies, defective verification and certification of non-forum shopping, missing complaint, and counsel’s IBP receipt omission.
- September 7, 2011: CA denied petitioners’ motion for reconsideration.
- August 30, 2017: Supreme Court resolved the Peti