ALFONSO SINGSON CORTAL VS INAKI LARRAZABAL G.R. No. 199107. (Digest)

ALFONSO SINGSON CORTAL VS INAKI LARRAZABAL G.R. No. 199107. August 30, 2017,

 Leonen, J. 

Procedural rules "are tools designed to facilitate the adjudication of cases [so] [c]ourts and litigants alike are thus enjoined to abide strictly by the rules." They provide a system for forestalling arbitrariness, caprice, despotism, or whimsicality in dispute settlement. Thus, they are not to be ignored to suit the interests of a party. Their disregard cannot be justified by a sweeping reliance on a "policy of liberal construction." 

FACTS:

The assailed Court of Appeals September 30, 2010 Resolution dismissed petitioners' appeal under Rule 43 of the 1997 Rules of Civil Procedure on account of several technical defects. First was an inconsistency between the listing of petitioners' names in their prior Motion for Extension of Time and subsequent Petition for Review, in which the accompanying verification and certification of non-forum shopping were laden with this same inconsistency and other defects. Second was the non--inclusion of the original Complaint filed by the adverse party, now private respondent Inaki A. Larrazabal Enterprises, before the Regional Agrarian Reform Adjudicator of the Department of Agrarian Reform. And last was petitioners' counsel's failure to indicate the place of issue of the official receipt of his payment of annual membership dues to the Integrated Bar of the Philippines

ISSUE: 

Whether or not the dismissal of petitioners' appeal was justified by the errors noted by the Court of Appeals.

RULING: 

No, the dismissal was not justified by the errors. Procedural rules "are tools designed to facilitate the adjudication of cases [so] [c]ourts and litigants alike are thus enjoined to abide strictly by the rules." They provide a system for forestalling arbitrariness, caprice, despotism, or whimsicality in dispute settlement. Thus, they are not to be ignored to suit the interests of a party. Their disregard cannot be justified by a sweeping reliance on a "policy of liberal construction." Still, this Court has stressed that every party litigant must be afforded the fullest opportunity to properly ventilate and argue his or her case, "free from the constraints of technicalities."34 Rule 1, Section 6 of the Rules of Court expressly stipulates their liberal construction to the extent that justice is better served. In this case, the Court of Appeals was harsh in denying petitioners the opportunity to exhaustively ventilate and argue their case. Rather than dwelling on procedural minutiae, the Court of Appeals should have been impelled by the greater interest of justice. It should have enabled a better consideration of the intricate issues of the application of the Comprehensive Agrarian Reform Law, social justice, expropriation, and just compensation. The reversals of rulings at the level of the DARAB could have been taken as an  indication that the matters at stake were far from being so plain that they should be ignored on mere technicalities. The better part of its discretion dictated a solicitous stance towards petitioners.


Source:
DEAN’S CIRCLE 2019 – UST FACULTY OF CIVIL LAW, retrieved April 24, 2020, from https://irp-cdn.multiscreensite.com/7dcde495/files/uploaded/Civil%20Procedure_MwNwIo5Rs6cBBO1gwlro.pdf