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GR No. 197832

2013-10-02

REYES, J.

In exceptional cases, the Court has in fact relaxed the period for perfecting an appeal on grounds of substantial justice or when there are other special and meritorious circumstances and issues.[15] Thus, in Remulla v. Manlongat,[16] the Court considered the one-day late filing of the prosecution's notice of appeal as excusable given the diligent efforts exerted by the private prosecutor in following up its filing with the public prosecutor.

GR No. 164255

2011-09-07

SPS. ELBE LEBIN AND ERLINDA LEBIN v. VILMA S. MIRASOL

BERSAMIN, J.

The right to appeal is a mere statutory privilege, and should be exercised only in the manner prescribed by law.[36] The statutory nature of the right to appeal requires the one who avails himself of it to strictly comply with the statutes or rules that are considered indispensable interdictions against needless delays and for an orderly discharge of judicial business. In the absence of highly exceptional circumstances warranting their relaxation, like when the loftier demands of substantial justice and equity require the relaxation,[37] or when there are other special and meritorious circumstances and issues,[38] such statutes or rules should remain inviolable.[39]

GR No. 187872

2010-11-17

STRATEGIC ALLIANCE DEVELOPMENT CORPORATION v. STAR INFRASTRUCTURE DEVELOPMENT CORPORATION ET AL.

PEREZ, J.

The rule is settled that rules of procedure ought not to be applied in a very rigid, technical sense,[52] for they have been adopted to help secure - not override - substantial justice.[53] Considering that litigation is not a game of technicalities[54] courts have been exhorted, time and again, to afford every litigant the amplest opportunity for the proper and just determination of his case free from the constraints of technicalities. Since rules of procedure are mere tools designed to facilitate the attainment of justice, it is well recognized that courts are empowered to suspend its rules, when the rigid application thereof tends to frustrate rather than promote the ends of justice.[55] No less than Section 3, Rule 1 of the Interim Rules provides that the provisions thereof are to "be liberally construed in order to promote their objective of securing a just, summary, speedy and inexpensive determination of every action or proceeding."

GR No. 159132

2008-12-18

FE CAYAO-LASAM v. SPS. CLARO AND EDITHA RAMOLETE

AUSTRIA-MARTINEZ, J.

Whatever doubt was created by the previous provision was settled with said amendment. It is axiomatic that the right to appeal is not a natural right or a part of due process, but a mere statutory privilege that may be exercised only in the manner prescribed by law.[28] In this case, the clear intent of the amendment is to render the right to appeal from a decision of the Board available to both complainants and respondents.

GR No. 169498

2008-12-11

OSCAR DELOS SANTOS v. CA

CHICO-NAZARIO, J.

Moreover, since the case at bar resonates with a piercing and urgent call for justice for a four-year-old boy seriously crippled by the accident caused by the negligence of Sagosoy, the Court is persuaded to excuse the procedural flaw so it could fully heed the call. Laws and rules should be interpreted and applied not in a vacuum or in isolated abstraction, but in light of surrounding circumstances and attendant facts in order to afford justice to all. This Court is not impervious to instances when rules of procedure must yield to the loftier demands of substantial justice and equity. Procedural rules are mere tools designed to facilitate the attainment of justice; their application must be liberalized to promote public interest.[26]

GR No. 136972

2008-03-28

RAMIREZ

NACHURA, J.

[20] Remulla v. Manlongat, G.R. No. 148189, November 11, 2004, 422 SCRA 226, 236.

GR NO. 143337

2007-04-02

URBANA T. GUY YOCHE v. NOEL GUY YOCHE

SANDOVAL-GUTIERREZ, J.

In fine, the Court of Appeals should not have dismissed the petition for certiorari on the ground of technicality. After all, the rules of procedure should not be applied in a very rigid, technical sense, their only purpose being to help secure substantial justice to the parties.[5]

GR NO. 153057

2006-08-07

MR. v. G.V.T. ENGINEERING SERVICES

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]

GR NO. 165711

2006-06-30

HERMOSO ARRIOLA v. SANDIGANBAYAN

YNARES-SANTIAGO, J.

However, the rules of procedure ought not to be applied in a very rigid, technical sense for they have been adopted to help secure not override substantial justice.[16] This Court has repeatedly stressed that the ends of justice would be served better when cases are determined, not on mere technicality or some procedural nicety, but on the merits after all the parties are given full opportunity to ventilate their causes and defenses. Lest it be forgotten, dismissal of appeals purely on technical grounds is frowned upon.[17]

GR NO. 161110

2006-03-30

PAL EMPLOYEES SAVINGS v. PHILIPPINE AIRLINES

PANGANIBAN, CJ

Being mere tools to enforce justice, procedural rules cannot be blindly followed if unwarranted by the circumstances. [33] Under the present factual circumstances, the staying of the interlocutory award of P44,488,716.41 was proper.

GR NO. 153756

2006-01-30

ATTY. FEDERICO CALO v. SPS. JACINTA VILLANUEVA AND JOSE VILLANUEVA

TINGA, J.

We agree. Dismissal of appeals purely on technical grounds is frowned upon.[16]

GR NO. 153756

2006-01-30

ATTY. FEDERICO CALO v. SPS. JACINTA VILLANUEVA AND JOSE VILLANUEVA

TINGA, J.

The rules of procedure ought not to be applied in a very rigid, technical sense, for they have been adopted to help secure not override substantial justice. [27] For this reason, courts must proceed with caution so as not to deprive a party of statutory appeal; rather, they must ensure that all litigants are granted the amplest opportunity for the proper and just ventilation of their causes, free from the constraint of technicalities.[28]

GR No. 142308

2005-11-15

SPS. REV. ELMER J. BAÑES AND ANGELA BAÑES v. LUTHERAN CHURCH IN PHILIPPINES

AUSTRIA-MARTINEZ, J.

True, a pro forma motion for reconsideration does not suspend the running of the period to appeal.[34] However, it is also axiomatic that Rules on the perfection of appeals must occasionally yield to the loftier ends of substantial justice and equity.[35] In the present case, petitioners filed their motion for extension of time to file a petition for review within 15 days from receipt of the denial of their motion for reconsideration of the decision in CA-G.R. SP No. 44333, which was granted. Then they filed their petition for review with this Court within the extended period. Under the premises and considering the merits of the case which ultimately negate the finding of the CA that the motion for reconsideration was pro forma, justice would be better served if we consider the present petition for review as duly filed.

	GR No. 197832 2013-10-02	ANITA RAMIREZ v. PEOPLE REYES, J.
In exceptional cases, the Court has in fact relaxed the period for perfecting an appeal on grounds of substantial justice or when there are other special and meritorious circumstances and issues.[15] Thus, in Remulla v. Manlongat,[16] the Court considered the one-day late filing of the prosecution's notice of appeal as excusable given the diligent efforts exerted by the private prosecutor in following up its filing with the public prosecutor.
	GR No. 164255 2011-09-07	SPS. ELBE LEBIN AND ERLINDA LEBIN v. VILMA S. MIRASOL BERSAMIN, J.
The right to appeal is a mere statutory privilege, and should be exercised only in the manner prescribed by law.[36] The statutory nature of the right to appeal requires the one who avails himself of it to strictly comply with the statutes or rules that are considered indispensable interdictions against needless delays and for an orderly discharge of judicial business. In the absence of highly exceptional circumstances warranting their relaxation, like when the loftier demands of substantial justice and equity require the relaxation,[37] or when there are other special and meritorious circumstances and issues,[38] such statutes or rules should remain inviolable.[39]
	GR No. 187872 2010-11-17	STRATEGIC ALLIANCE DEVELOPMENT CORPORATION v. STAR INFRASTRUCTURE DEVELOPMENT CORPORATION ET AL. PEREZ, J.
The rule is settled that rules of procedure ought not to be applied in a very rigid, technical sense,[52] for they have been adopted to help secure - not override - substantial justice.[53] Considering that litigation is not a game of technicalities[54] courts have been exhorted, time and again, to afford every litigant the amplest opportunity for the proper and just determination of his case free from the constraints of technicalities. Since rules of procedure are mere tools designed to facilitate the attainment of justice, it is well recognized that courts are empowered to suspend its rules, when the rigid application thereof tends to frustrate rather than promote the ends of justice.[55] No less than Section 3, Rule 1 of the Interim Rules provides that the provisions thereof are to "be liberally construed in order to promote their objective of securing a just, summary, speedy and inexpensive determination of every action or proceeding."
	GR No. 159132 2008-12-18	FE CAYAO-LASAM v. SPS. CLARO AND EDITHA RAMOLETE AUSTRIA-MARTINEZ, J.
Whatever doubt was created by the previous provision was settled with said amendment. It is axiomatic that the right to appeal is not a natural right or a part of due process, but a mere statutory privilege that may be exercised only in the manner prescribed by law.[28] In this case, the clear intent of the amendment is to render the right to appeal from a decision of the Board available to both complainants and respondents.
	GR No. 169498 2008-12-11	OSCAR DELOS SANTOS v. CA CHICO-NAZARIO, J.
Moreover, since the case at bar resonates with a piercing and urgent call for justice for a four-year-old boy seriously crippled by the accident caused by the negligence of Sagosoy, the Court is persuaded to excuse the procedural flaw so it could fully heed the call. Laws and rules should be interpreted and applied not in a vacuum or in isolated abstraction, but in light of surrounding circumstances and attendant facts in order to afford justice to all. This Court is not impervious to instances when rules of procedure must yield to the loftier demands of substantial justice and equity. Procedural rules are mere tools designed to facilitate the attainment of justice; their application must be liberalized to promote public interest.[26]
	GR No. 136972 2008-03-28	RAMIREZ NACHURA, J.
[20] Remulla v. Manlongat, G.R. No. 148189, November 11, 2004, 422 SCRA 226, 236.
	GR NO. 143337 2007-04-02	URBANA T. GUY YOCHE v. NOEL GUY YOCHE SANDOVAL-GUTIERREZ, J.
In fine, the Court of Appeals should not have dismissed the petition for certiorari on the ground of technicality. After all, the rules of procedure should not be applied in a very rigid, technical sense, their only purpose being to help secure substantial justice to the parties.[5]
	GR NO. 153057 2006-08-07	MR. v. G.V.T. ENGINEERING SERVICES 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]
	GR NO. 165711 2006-06-30	HERMOSO ARRIOLA v. SANDIGANBAYAN YNARES-SANTIAGO, J.
However, the rules of procedure ought not to be applied in a very rigid, technical sense for they have been adopted to help secure not override substantial justice.[16] This Court has repeatedly stressed that the ends of justice would be served better when cases are determined, not on mere technicality or some procedural nicety, but on the merits after all the parties are given full opportunity to ventilate their causes and defenses. Lest it be forgotten, dismissal of appeals purely on technical grounds is frowned upon.[17]
	GR NO. 161110 2006-03-30	PAL EMPLOYEES SAVINGS v. PHILIPPINE AIRLINES PANGANIBAN, CJ
Being mere tools to enforce justice, procedural rules cannot be blindly followed if unwarranted by the circumstances. [33] Under the present factual circumstances, the staying of the interlocutory award of P44,488,716.41 was proper.
	GR NO. 153756 2006-01-30	ATTY. FEDERICO CALO v. SPS. JACINTA VILLANUEVA AND JOSE VILLANUEVA TINGA, J.
We agree. Dismissal of appeals purely on technical grounds is frowned upon.[16]
	GR NO. 153756 2006-01-30	ATTY. FEDERICO CALO v. SPS. JACINTA VILLANUEVA AND JOSE VILLANUEVA TINGA, J.
The rules of procedure ought not to be applied in a very rigid, technical sense, for they have been adopted to help secure not override substantial justice. [27] For this reason, courts must proceed with caution so as not to deprive a party of statutory appeal; rather, they must ensure that all litigants are granted the amplest opportunity for the proper and just ventilation of their causes, free from the constraint of technicalities.[28]
	GR No. 142308 2005-11-15	SPS. REV. ELMER J. BAÑES AND ANGELA BAÑES v. LUTHERAN CHURCH IN PHILIPPINES AUSTRIA-MARTINEZ, J.
True, a pro forma motion for reconsideration does not suspend the running of the period to appeal.[34] However, it is also axiomatic that Rules on the perfection of appeals must occasionally yield to the loftier ends of substantial justice and equity.[35] In the present case, petitioners filed their motion for extension of time to file a petition for review within 15 days from receipt of the denial of their motion for reconsideration of the decision in CA-G.R. SP No. 44333, which was granted. Then they filed their petition for review with this Court within the extended period. Under the premises and considering the merits of the case which ultimately negate the finding of the CA that the motion for reconsideration was pro forma, justice would be better served if we consider the present petition for review as duly filed.

EMERITO REMULLA v. JOSELITO DP. MANLONGAT