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JIMMY L. BARNES v. MA. LUISA C. QUIJANO PADILLA

This case has been cited 16 times or more.

2014-10-22
BERSAMIN, J.
However, the Court will not be dispensing true and effective justice if it denies the petition for review on the basis alone of the absence of the judicial confirmation of the sale. Although procedural rules are not to be belittled or disregarded considering that they insure an orderly and speedy administration of justice, it is equally true that litigation is not a game of technicalities. Law and jurisprudence grant to the courts the prerogative to relax compliance with procedural rules of even the most mandatory character, mindful of the duty to reconcile both the need to speedily put an end to litigation and the parties' right to an opportunity to be heard.[38] The Rules of Court itself calls for a liberal construction of its rules with the view of promoting their objective of securing a just, speedy and inexpensive disposition of every action and proceeding.[39]
2013-01-28
VILLARAMA, JR., J.
The assailed CA resolution upheld the general rule that the filing of a motion for extension of time to file a motion for reconsideration in the CA does not toll the fifteen-day period to appeal, citing Habaluyas Enterprises, Inc. v. Japson.[32]  However, in previous cases we suspended this rule in order to serve substantial justice.[33]
2009-09-18
CHICO-NAZARIO, J.
An action for reconveyance or accion reivindicatoria has no effect and can exist at the same time as ejectment cases involving the same property.[9] This is because the only issue to be resolved in an unlawful detainer case is physical or material possession of the property involved, independent of any claim of ownership by any of the parties involved.[10] Ejectment cases are designed to summarily restore physical possession to one who has been illegally deprived of such possession, without prejudice to the settlement of the parties' opposing claims of juridical possession in appropriate proceedings.[11] The question of ownership may only be provisionally ruled upon for the sole purpose of determining who is entitled to possession de facto.[12]
2009-06-05
BRION, J.
This rule, however, is not absolute and admits of exceptions based on a liberal reading of the rule. In Barnes v. Padilla,[16] (a case very similar to the present case and where the CA found the petitioner guilty of forum shopping), the Court opted for the exception. The petitioner in Barnes, instead of filing a motion for reconsideration of the CA's decision, filed a motion for extension of time to file a motion for reconsideration. The CA denied the motion because of the rule disallowing an extension of time to file a motion for reconsideration. This Court, however, looked into the merits of the forum shopping charge and opted to suspend the prohibition against a motion for extension of time to file a motion for reconsideration, after it found the petitioner not liable for forum shopping. In opting for the liberal application of the rules in the interest of equity and justice, the Court held that we "cannot look with favor on a course of action which would place the administration of justice in a straight jacket for then the result would be a poor kind of justice if there would be justice at all."
2009-05-08
TINGA, J.
This issue is hardly a novel one.  It has been laid to rest by heaps of cases iterating the principle that a judgment rendered in an ejectment case shall not bar an action between the same parties respecting title to the land or building nor shall it be conclusive as to the facts therein found in a case between the same parties upon a different cause of action involving possession.[24]
2009-02-10
CHICO-NAZARIO, J.
Nevertheless, the Rules of Court itself calls for its liberal construction, with the view of promoting their objective of securing a just, speedy and inexpensive disposition of every action and proceeding.[10] The Court is fully aware that procedural rules are not to be belittled or simply disregarded for these prescribed procedures insure an orderly and speedy administration of justice. However, it is equally true that litigation is not merely a game of technicalities. Law and jurisprudence grant to courts the prerogative to relax compliance with procedural rules of even the most mandatory character, mindful of the duty to reconcile both the need to put an end to litigation speedily and the parties' right to an opportunity to be heard.[11]
2008-08-22
AUSTRIA-MARTINEZ, J.
Another matter raised by petitioner relating to the jurisdiction of the MeTC is the personality of respondents to give notice to vacate and to file an ejectment case.  The Court need not belabor the point for it is well-settled that, as vendees of the property, respondents were placed in the shoes of the original lessor LKTSI and vested with the right to evict petitioner as the lessee from the premises.[80]  Whether the transfer of the property to respondents was valid is of no moment, for all that is to be resolved in the ejectment case is whether the latter are entitled to the material possession of the property.[81]
2008-08-11
AUSTRIA-MARTINEZ, J.
The Court is fully aware that procedural rules are not to be belittled or simply disregarded, for these prescribed procedures insure an orderly and speedy administration of justice.[21] However, it is equally settled that litigation is not merely a game of technicalities.[22] Rules of procedure should be viewed as mere tools designed to facilitate the attainment of justice.[23] Their strict and rigid application, which would result in technicalities that tend to frustrate rather than promote substantial justice, must always be eschewed.[24] Even the Rules of Court reflect this principle.[25]
2008-07-28
REYES, R.T., J.
Nonetheless, it is also true that procedural rules are mere tools designed to facilitate the attainment of justice. Their strict and rigid application should be relaxed when they hinder rather than promote substantial justice. Public policy dictates that court cases should, as much as possible, be resolved on the merits not on mere technicalities. Substantive justice trumps procedural rules. In Barnes v. Padilla,[26] this Court held:Let it be emphasized that the rules of procedure should be viewed as mere tools designed to facilitate the attainment of justice. Their strict and rigid application, which would result in technicalities that tend to frustrate rather than promote substantial justice, must always be eschewed. Even the Rules of Court reflect this principle. The power to suspend or even disregard rules can be so pervasive and compelling as to alter even that which this Court itself has already declared to be final x x x.
2008-05-07
CARPIO, J.
Rules of procedure are merely tools designed to facilitate the attainment of justice.[10] If the application of the Rules would tend to frustrate rather than to promote justice, it is always within our power to suspend the rules or except a particular case from its operation.[11] Law and jurisprudence grant to courts the prerogative to relax compliance with the procedural rules, even the most mandatory in character, mindful of the duty to reconcile the need to put an end to litigation speedily and the parties' right to an opportunity to be heard.[12]
2008-03-28
REYES, R.T., J.
It is true that appeals are mere statutory privileges which should be exercised only in the manner required by law. To be sure, strict compliance with rules of procedure is essential to the administration of justice. Nonetheless, technical rules of procedures are mere tools designed to facilitate the attainment of justice. Their strict and rigid application should be relaxed when they hinder rather than promote substantial justice. Cases should, as much as possible, be resolved on the merits, not on mere technicalities. In Barnes v. Padilla,[32] this Court held:Let it be emphasized that the rules of procedure should be viewed as mere tools designed to facilitate the attainment of justice. Their strict and rigid application, which would result in technicalities that tend to frustrate rather than promote substantial justice, must always be eschewed. Even the Rules of Court reflect this principle. The power to suspend or even disregard rules can be so pervasive and compelling as to alter even that which this Court itself has already declared to be final x x x.
2007-06-08
NACHURA, J.
Courts have the prerogative to relax procedural rules of even the most mandatory character, mindful of the duty to reconcile both the need to speedily put an end to litigation and the parties' right to due process. In numerous cases, this Court has allowed liberal construction of the rules when to do so would serve the demands of substantial justice and equity.[20] In Aguam v. Court of Appeals, the Court explained: The court has the discretion to dismiss or not to dismiss an appellant's appeal. It is a power conferred on the court, not a duty. The "discretion must be a sound one, to be exercised in accordance with the tenets of justice and fair play, having in mind the circumstances obtaining in each case." Technicalities, however, must be avoided. The law abhors technicalities that impede the cause of justice. The court's primary duty is to render or dispense justice. "A litigation is not a game of technicalities." "Lawsuits unlike duels are not to be won by a rapier's thrust. Technicality, when it deserts its proper office as an aid to justice and becomes its great hindrance and chief enemy, deserves scant consideration from courts." Litigations must be decided on their merits and not on technicality. Every party litigant must be afforded the amplest opportunity for the proper and just determination of his cause, free from the unacceptable plea of technicalities. Thus, dismissal of appeals purely on technical grounds is frowned upon where the policy of the court is to encourage hearings of appeals on their merits and the rules of procedure ought not to be applied in a very rigid, technical sense; rules of procedure are used only to help secure, not override substantial justice. It is a far better and more prudent course of action for the court to excuse a technical lapse and afford the parties a review of the case on appeal to attain the ends of justice rather than dispose of the case on technicality and cause a grave injustice to the parties, giving a false impression of speedy disposal of cases while actually resulting in more delay, if not a miscarriage of justice.[21] Third, while we affirm that the subject lease agreement is a contract of adhesion, such a contract is not void per se. It is as binding as any ordinary contract. A party who enters into an adhesion contract is free to reject the stipulations entirely.[22] If the terms thereof are accepted without objection, then the contract serves as the law between the parties.
2006-12-06
VELASCO, JR., J.
The case of Barnes v. Padilla[17] elucidates the rationale behind the exercise by this Court of the power to relax, or even suspend, the application of the rules of procedure:Let it be emphasized that the rules of procedure should be viewed as mere tools designed to facilitate the attainment of justice. Their strict and rigid application, which would result in technicalities that tend to frustrate rather than promote substantial justice, must always be eschewed. Even the Rules of Court reflect this principle. The power to suspend or even disregard rules can be so pervasive and compelling as to alter even that which this Court itself has already declared to be final x x x.
2006-09-19
AZCUNA, J.
Such action has "for its object the recovery of the physical possession"[23] or determination of "who is entitled to possession de facto"[24] "of the leased premises (the house)[,] not the ownership of the lot"[25] and not its "legal possession, in the sense contemplated in civil law."[26] In fact, "any finding of the court regarding the issue of ownership is merely provisional and not conclusive."[27] The judgment rendered "shall not bar an action between the same parties respecting title to the land or building nor shall it be conclusive as to the facts therein found in a case between the same parties upon a different cause of action involving possession."[28]
2006-08-07
AUSTRIA-MARTINEZ, J.
This Court has held time and again that rules of procedure should be viewed as mere tools designed to aid the courts in the speedy, just and inexpensive determination of the cases before them.[13] Liberal construction of the rules and the pleadings is the controlling principle to effect substantial justice.[14] In fact, this Court is not impervious to instances when rules of procedure must yield to the loftier demands of substantial justice and equity.[15] Citing Aguam v. Court of Appeals[16], this Court held in Barnes v. Quijano[17] that:The law abhors technicalities that impede the cause of justice. The court's primary duty is to render or dispense justice. "A litigation is not a game of technicalities." "Lawsuits unlike duels are not to be won by a rapier's thrust. Technicality, when it deserts its proper office as an aid to justice and becomes its great hindrance and chief enemy, deserves scant consideration from courts." Litigations must be decided on their merits and not on technicality. Every party litigant must be afforded the amplest opportunity for the proper and just determination of his cause, free from the unacceptable plea of technicalities. Thus, dismissal of appeals purely on technical grounds is frowned upon where the policy of the court is to encourage hearings of appeals on their merits and the rules of procedure ought not to be applied in a very rigid, technical sense; rules of procedure are used only to help secure, not override substantial justice. It is a far better and more prudent course of action for the court to excuse a technical lapse and afford the parties a review of the case on appeal to attain the ends of justice rather than dispose of the case on technicality and cause a grave injustice to the parties, giving a false impression of speedy disposal of cases while actually resulting in more delay, if not a miscarriage of justice.[18]
2005-10-19
QUISUMBING, J.
Prefatorily, this case started with a complaint for ejectment filed with the MeTC. In previous cases, this Court consistently held that the only issue for resolution in an ejectment case is physical or material possession of the property involved, independent of any claim of ownership by any of the party litigants.[12] Ejectment cases are designed to summarily restore physical possession to one who has been illegally deprived of such possession, without prejudice to the settlement of the parties' opposing claims of juridical possession in appropriate proceedings.[13] We also said that the question of ownership may be provisionally ruled upon for the sole purpose of determining who is entitled to possession de facto.[14]