Sebastian vs. Morales 445 Phil 595, 605

Facts:

Private respondents are the heirs of the late Guillermo Sarenas, who died intestate. During his lifetime, Guillermo owned agricultural landholdings, all located in Samon and Mayapyap Sur, Cabanatuan City.

Private respondents filed an application with the Department of Agrarian Reform (DAR) for retention of over five hectares of the late Guillermo’s landholdings. Among the lots which private respondents sought to retain under Section 6 of the Comprehensive Agrarian Reform Law (R.A. No. 6657). the DAR Regional Office in San Fernando, Pampanga granted private respondents’ application.

petitioner Sebastian moved for reconsideration of the foregoing order before the DAR Regional Director. The DAR Regional Director found that the order dated June 6, 1997 in was contrary to law. He then issued a new order which instead allowed private respondents to retain a parcel of land with an area of 4.9993 hectares, covered by TCT No. 143564, located at San Ricardo, Talavera, Nueva Ecija.

Private respondents then appealed the order to the DAR Secretary. The Secretary of Agrarian Reform set aside the order and in lieu thereof issued a new one.

Petitioner Sebastian then filed a motion for reconsideration, but this motion was denied, petitioners filed a special civil action for certiorari and prohibition, with prayer for writ of preliminary mandatory injunction with the Court of Appeals. the Court of Appeals, without going into the merits of the case, dismissed it after finding that “petitioners pursued the wrong mode of appeal.

Petitioners then timely moved for reconsideration, but the appellate court denied their motion. Hence this case.

Petitioners admit that there was error in the remedy resorted to before the Court of Appeals. They insist, however, that a perusal of their initiatory pleading would show that said pleading contained all the features and contents for a petition for review under Rule 43, Section 6 of the 1997 Rules of Civil Procedure. Hence, the court a quo should have treated their special civil action for certiorari and prohibition under Rule 65 as a petition for review under Rule 43, since dismissals based on technicalities are frowned upon. Petitioners contend that procedural rules are but a means to an end and should be liberally construed to effect substantial justice.

Issue:

Whether the CA committed a reversible error in not liberally applying the Rules of Court.

Held:

No, liberal construction of the rules is the controlling principle to effect substantial justice. Thus, litigations should, as much as possible, be decided on their merits and not on technicalities. This does not mean, however, that procedural rules are to be ignored or disdained at will to suit the convenience of a party. Procedural law has its own rationale in the orderly administration of justice, namely, to ensure the effective enforcement of substantive rights by providing for a system that obviates arbitrariness, caprice, despotism, or whimsicality in the settlement of disputes. Hence, it is a mistake to suppose that substantive law and procedural law are contradictory to each other, or as often suggested, that enforcement of procedural rules should never be permitted if it would result in prejudice to the substantive rights of the litigants.

Litigation is not a game of technicalities, but every case must be prosecuted in accordance with the prescribed procedure so that issues may be properly presented and justly resolved. Hence, rules of procedure must be faithfully followed except only when for persuasive reasons, they may be relaxed to relieve a litigant of an injustice not commensurate with his failure to comply with the prescribed procedure. Concomitant to a liberal application of the rules of procedure should be an effort on the part of the party invoking liberality to explain his failure to abide by the rules.

The SC agreed with the appellate court that petitioners’ reliance on Section 54 of R.A. No. 6657 “is not merely a mistake in the designation of the mode of appeal, but clearly an erroneous appeal from the assailed Orders.