This case has been cited 5 times or more.
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2012-08-29 |
BERSAMIN, J. |
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| The principle of substantial compliance recognizes that exigencies and situations do occasionally demand some flexibility in the rigid application of the rules of procedure and the laws.[26] That rules of procedure may be mandatory in form and application does not forbid a showing of substantial compliance under justifiable circumstances,[27] because substantial compliance does not equate to a disregard of basic rules. For sure, substantial compliance and strict adherence are not always incompatible and do not always clash in discord. The power of the Court to suspend its own rules or to except any particular case from the operation of the rules whenever the purposes of justice require the suspension cannot be challenged.[28] In the interest of substantial justice, even procedural rules of the most mandatory character in terms of compliance are frequently relaxed. Similarly, the procedural rules should definitely be liberally construed if strict adherence to their letter will result in absurdity and in manifest injustice, or where the merits of a party's cause are apparent and outweigh considerations of non-compliance with certain formal requirements.[29] It is more in accord with justice that a party-litigant is given the fullest opportunity to establish the merits of his claim or defense than for him to lose his life, liberty, honor or property on mere technicalities. Truly, the rules of procedure are intended to promote substantial justice, not to defeat it, and should not be applied in a very rigid and technical sense.[30] Petitioner urges the Court to resolve the apparent conflict between the rulings in Heirs of Pedro Cabais v. Court of Appeals[31] (Cabais) and in Heirs of Ignacio Conti v. Court of Appeals[32] (Conti) establishing filiation through a baptismal certificate.[33] | |||||
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2009-04-16 |
QUISUMBING, J. |
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| The information in Criminal Case No. 00-1879 specifically alleged that AAA was a minor at the time she was raped and that the offender, Dionisio, is her guardian. During the trial, the prosecution proved the presence of the qualifying circumstances of minority and relationship through documentary and testimonial evidence.[43] As shown in her Certificate of Live Birth, AAA was born on September 3, 1989. Therefore, at the time the rape was committed on October 9, 2000, she was 11 years old. Her relationship to Dionisio was likewise proved by the testimonies of AAA, BBB and all three accused. Dionisio's defense that he and BBB merely simulated AAA's Certificate of Live Birth should not be given credence since a Certificate of Live Birth is a public document[44] which has in its favor the presumption of regularity. Thus, he who alleges forgery must prove the same by clear, positive and convincing evidence.[45] | |||||
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2008-09-26 |
CHICO-NAZARIO, J. |
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| What is glaring in the subdivision plans of TCTs No. 6886 and No. 6887, which are public documents, are the annotations therein stating that the lots occupied by Ruben and Leopoldo are untenanted. The subdivision plans, being public documents, are entitled to a presumption of truth as to the recitals contained therein.[20] Since the subdivision plans state that the lots occupied by Ruben and Leopoldo are not tenanted, a high degree of proof is needed to overthrow the presumption of truth contained in said subdivision plans. This is pursuant to the rule[21] that entries in official records made in the performance of duty by a public officer are prima facie evidence of the truth of the facts therein stated.[22] The evidentiary nature of such document must, therefore, be sustained in the absence of strong, complete and conclusive proof of its falsity. It also bears stressing that the Bureau of Lands, an agency of the executive branch tasked with the classification of lands, issued the subdivision plans certifying that the disputed lots were not tenanted. The Bureau arrived at the conclusion that the said lands were untenanted after it conducted a survey on 5 September 1985. | |||||
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2008-04-18 |
YNARES-SATIAGO, J. |
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| In PELIÑO's case, we find that evidence of her guilt is strong. The evidence does not show that CUAKI is Go's son, such that it could be believed that PELIÑO, who claims to act as the de facto guardian and administrator of the boy's properties, received a total of P11,640,000.00 from 1985 up to 2000 as financial support from Go, which she used to purchase some of the properties in question. Alfonso and PELIÑO are CUAKI's parents, as the latter's certificate of live birth shows. Although the same has been denied by PELIÑO herself, who claims that CUAKI's birth certificate is a forged document, the said document subsists and has not been duly voided. Being a public document, CUAKI's certificate of live birth offers prima facie evidence of filiation and a high degree of proof is needed to overthrow the presumption of truth contained therein. This is pursuant to the rule that entries in official records made in the performance of his duty by a public officer are prima facie evidence of the facts therein stated. The evidentiary nature of such document must, therefore, be sustained in the absence of strong, complete and conclusive proof of its falsity or nullity.[41] | |||||
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2001-12-04 |
QUISUMBING, J. |
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| ...a baptismal certificate is evidence only to prove the administration of the sacrament on the dates therein specified, but not the veracity of the declarations therein stated with respect to [a person's] kinsfolk. The same is conclusive only of the baptism administered, according to the rites of the Catholic Church, by the priest who baptized subject child, but it does not prove the veracity of the declarations and statements contained in the certificate concerning the relationship of the person baptized.[23] | |||||