Case Summary (G.R. No. 214794)
Background and Antecedents
The case arises from a complex transaction involving the Spouses Narciso and Josephine Victoriano, who purchased a property in Nakagang, Sabangan, Mountain Province from the Philippine National Bank on January 29, 2003. This transaction originally recorded a sales price of Php 150,000. Shortly afterwards, a second Deed of Sale was executed on February 12, 2003, reflecting a higher price of Php 850,000, ostensibly to affect tax obligations.
After the Spouses Victoriano submitted the January Deed of Sale for taxation, a complaint was lodged by Juniper Dominguez against them and the bank's branch manager, Benedicto Vasquez. Dominguez alleged that the parties had falsified public documents to evade tax liabilities due on the actual sale price.
Findings of the Ombudsman
Initially, the Office of the Ombudsman (OMB) dismissed Dominguez's complaint on May 19, 2011, noting that the February Deed of Sale had been submitted to the Bureau of Internal Revenue (BIR) and bore a proper stamp. However, the decision was reversed on November 14, 2011, after a motion for reconsideration was filed by Dominguez. The OMB found sufficient evidence suggesting the Spouses Victoriano were guilty of dishonesty for their actions and ordered their dismissal from government service, along with criminal charges for falsification.
Court of Appeals Ruling
Dissatisfied, Victoriano sought to appeal the OMB's ruling, but the Court of Appeals dismissed his petition outright on technical grounds, primarily due to several procedural shortcomings, including an incomplete statement of material dates and improper certification regarding non-forum shopping. The CA later denied Victoriano’s motion for reconsideration on October 3, 2014, thereby affirming its previous ruling.
Issue Presented
The petitioner subsequently raised the main issue to the Supreme Court: whether the Court of Appeals erred in its strict dismissal of the petition, primarily based on technical procedural violations rather than addressing the substantive issues.
Supreme Court's Analysis
The Supreme Court acknowledged Victoriano's procedural missteps but emphasized the overarching need to dispense justice. It cited that while adherence to procedural rules is critical, dismissals based solely on technicalities are frowned upon, especially where substantial justice is at stake.
Substantial Compliance with Procedural Rules
The Supreme Court evaluated each alleged procedural defect:
Statement of Material Dates: The Court concluded that although Victoriano’s statement was incomplete, he had specified that he received the resolution denying his motion for reconsideration on October 7, 2013, and filed the appeal within the timeframe allowed by the rules. This was deemed sufficient to satisfy the requirements.
Personal Service Explanation: The absence of a written affidavit explaining the choice of service mode was excused, given the impracticality of personal service due to geographical distance.
Verification of Allegations: The Court found that the verification stating the truthfulness of allegations based on personal knowledge sufficed, even without an attestation that it was based on authentic records.
Certification against Forum Shopping: The certification's omission regarding the absence of other pending actions was considered a minor
Case Syllabus (G.R. No. 214794)
Overview of the Case
- The case revolves around a Petition for Review on Certiorari filed by Narciso Victoriano against Juniper Dominguez, contesting the dismissal of his petition by the Court of Appeals (CA) due to procedural lapses.
- The CA dismissed Victoriano's petition based on technical grounds, particularly citing incomplete documentation and verification issues.
Background of the Case
- On January 29, 2003, Narciso and Josephine Victoriano (Spouses Victoriano) purchased a property from the Philippine National Bank (PNB) in Bontoc, Mountain Province, for Php 150,000.00.
- A second Deed of Sale was executed on February 12, 2003, reflecting a purchase price of Php 850,000.00, which was submitted for taxation to the Bureau of Internal Revenue (BIR).
- Juniper Dominguez filed complaints against the Spouses Victoriano and Benedicto Vasquez (PNB Branch Manager) for falsification of public documents, alleging tax evasion due to the two different deeds of sale.
Proceedings Before the Ombudsman
- The Office of the Ombudsman (OMB) initially dismissed the complaints against the Spouses Victoriano and Vasquez in a Joint Resolution dated May 19, 2011.
- Following a Motion for Reconsideration filed by Dominguez, the OMB issued a Joint Order on November 14, 2011, reversing its earlier resolution, finding Victoriano guilty of dishonesty, and ordering his dismissal from government service.
Motions for Reconsideration
- Victoriano filed multiple motions for reconsideration, claiming the emergence of new evidence and contesting the OMB’s decision.
- The motions were ultimately denied, leading to Victoriano’s filing of a Petition for Review with the CA.