Lawyerly

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. 180551

2009-02-10

ERWIN H. REYES v. VS.NLRC

CHICO-NAZARIO, J.

In numerous cases,[12] the Court has allowed liberal construction of Section 11, Rule 13 of the Revised Rules of Court when doing so would be in the service of the demands of substantial justice and in the exercise of the equity jurisdiction of this Court. In one such case, Fulgencio v. National Labor Relations Commission,[13] this Court provided the following justification for its non-insistence on a written explanation as required by Section 11, Rule 13 of the Revised Rules of Court:The rules of procedure are merely tools designed to facilitate the attainment of justice. They were conceived and promulgated to effectively aid the court in the dispensation of justice. Courts are not slaves to or robots of technical rules, shorn of judicial discretion. In rendering justice, courts have always been, as they ought to be, conscientiously guided by the norm that on the balance, technicalities take a backseat against substantive rights, and not the other way around. Thus, if the application of the Rules would tend to frustrate rather than promote justice, it is always within our power to suspend the rules, or except a particular case from its operation.

GR No. 176405

2008-08-20

LEO WEE v. GEORGE DE CASTRO

CHICO-NAZARIO, J.

Petitioner's averment that the Court of Appeals should have dismissed respondents' Petition in light of the failure of their counsel to attach the Official Receipt of his updated payment of Integrated Bar of the Philippines (IBP) dues is now moot and academic, since respondents' counsel has already duly complied therewith. It must be stressed that judicial cases do not come and go through the portals of a court of law by the mere mandate of technicalities.[31] Where a rigid application of the rules will result in a manifest failure or miscarriage of justice, technicalities should be disregarded in order to resolve the case. [32]

GR No. 176995

2008-07-30

PABLO D. ACAYLAR v. DANILO G. HARAYO

CHICO-NAZARIO, J.

Accordingly, the parties are now given the amplest opportunity to fully ventilate their claims and defenses brushing aside technicalities in order to truly ascertain the merits of this case. Indeed, judicial cases do not come and go through the portals of a court of law by the mere mandate of technicalities.[26] Where a rigid application of the rules will result in a manifest failure or miscarriage of justice, technicalities should be disregarded in order to resolve the case. In Aguam v. Court of Appeals,[27] we ruled that: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." "Law suits, 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.

GR NO. 153721

2006-09-15

PHILIPPINE NATIONAL RAILWAYS v. MARIO RUSTIA

CORONA, J.

In Fulgencio, et al. v. NLRC,[16] we refused to dismiss the case on the ground that petitioners did not explain why they failed to personally serve their petition on private respondents. There, we declared that technicalities should take a backseat to substantive rights, not the other way around.

GR NO. 142937

2006-07-25

PHILIPPINE AMUSEMENT v. MARITA A. ANGARA

AUSTRIA-MARTINEZ, J.

As a rule, a party who did not appeal from a decision of a court cannot obtain affirmative relief other than that granted in the appealed decision.[5] This applies also to decisions of administrative or quasi-judicial tribunals.[6] In the present case, however, while respondents did not appeal from CSC Resolution No. 991110 dated May 27, 1999 which merely ordered reinstatement and that they raised the issue of backwages only in the present motion, these did not preclude them from praying for the monetary benefits provided by law. Where an ironhanded application of the rules will result in an unmistakable failure or miscarriage of justice, technicalities should be disregarded in order to resolve the case.[7] This Court is, therefore, constrained to relax the rules to give way to the supreme and overriding interest of labor and justice. Indeed, 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.[8]

GR NO. 142358

2006-01-31

GRAND PLACEMENT v. CA

AUSTRIA-MARTINEZ, J.

The Court has often stressed that rules of procedure are merely tools designed to facilitate the attainment of justice. They were conceived and promulgated to effectively aid the court in the dispensation of justice. Courts are not slaves to or robots of technical rules, shorn of judicial discretion. In rendering justice, courts have always been, as they ought to be, conscientiously guided by the norm that on the balance, technicalities take a backseat against substantive rights, and not the other way around. Thus, if the application of the Rules would tend to frustrate rather than promote justice, it is always within our power to suspend the rules or except a particular case from its operation.[29]

GR NO. 166429

2005-12-19

REPUBLIC v. HENRICK F. GINGOYON

TINGA, J.

The disqualification of a judge is a deprivation of his/her judicial power[73] and should not be allowed on the basis of mere speculations and surmises. It certainly cannot be predicated on the adverse nature of the judge's rulings towards the movant for inhibition, especially if these rulings are in accord with law. Neither could inhibition be justified merely on the erroneous nature of the rulings of the judge. We emphasized in Webb v. People:[74]

AM No. MTJ-99-1239

2005-07-29

VICENTE M. BATIC v. JUDGE VICTORIO L. GALAPON

AZCUNA, J.

Technical rules must give way to substantive rights. As held in Roberto Fulgencio, et al. v. National Labor Relations Commission and Raycor Aircontrol Systems, Inc.,[5]

GR NO. 157320

2005-06-28

KABANKALAN CATHOLIC COLLEGE v. KABANKALAN CATHOLIC COLLEGE UNION-PACIWU-TUCP

PANGANIBAN, J.

Necessarily, the validity of the arbitral award became the law of the case between the parties. Under this legal principle, whatever is irrevocably established as the controlling legal rule or decision between the same parties in the same case continues to be the law of the case, so long as the facts on which the decision was predicated continues.[22] Otherwise stated, the principle holds that once an appellate court has declared the law in a case, that declaration continues to hold even in a subsequent appeal.[23] Reasons of public policy, judicial orderliness and economy require such stability in the final judgments of courts or tribunals of competent jurisdiction.[24]

GR No. 138660

2004-02-05

HEIRS OF TRINIDAD DE LEON VDA. DE ROXAS v. CA

CARPIO, J.

Well-settled is the rule that when a court of competent jurisdiction has tried and decided a right or fact, so long as the decision remains unreversed, it is conclusive on the parties and those in privity with them.[11] More so where the Supreme Court has already decided the issue since the Court is the final arbiter of all justiciable controversies properly brought before it.[12] As held in Buaya v. Stronghold Insurance Co., Inc.:[13]

	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. 180551 2009-02-10	ERWIN H. REYES v. VS.NLRC CHICO-NAZARIO, J.
In numerous cases,[12] the Court has allowed liberal construction of Section 11, Rule 13 of the Revised Rules of Court when doing so would be in the service of the demands of substantial justice and in the exercise of the equity jurisdiction of this Court. In one such case, Fulgencio v. National Labor Relations Commission,[13] this Court provided the following justification for its non-insistence on a written explanation as required by Section 11, Rule 13 of the Revised Rules of Court:The rules of procedure are merely tools designed to facilitate the attainment of justice. They were conceived and promulgated to effectively aid the court in the dispensation of justice. Courts are not slaves to or robots of technical rules, shorn of judicial discretion. In rendering justice, courts have always been, as they ought to be, conscientiously guided by the norm that on the balance, technicalities take a backseat against substantive rights, and not the other way around. Thus, if the application of the Rules would tend to frustrate rather than promote justice, it is always within our power to suspend the rules, or except a particular case from its operation.
	GR No. 176405 2008-08-20	LEO WEE v. GEORGE DE CASTRO CHICO-NAZARIO, J.
Petitioner's averment that the Court of Appeals should have dismissed respondents' Petition in light of the failure of their counsel to attach the Official Receipt of his updated payment of Integrated Bar of the Philippines (IBP) dues is now moot and academic, since respondents' counsel has already duly complied therewith. It must be stressed that judicial cases do not come and go through the portals of a court of law by the mere mandate of technicalities.[31] Where a rigid application of the rules will result in a manifest failure or miscarriage of justice, technicalities should be disregarded in order to resolve the case. [32]
	GR No. 176995 2008-07-30	PABLO D. ACAYLAR v. DANILO G. HARAYO CHICO-NAZARIO, J.
Accordingly, the parties are now given the amplest opportunity to fully ventilate their claims and defenses brushing aside technicalities in order to truly ascertain the merits of this case. Indeed, judicial cases do not come and go through the portals of a court of law by the mere mandate of technicalities.[26] Where a rigid application of the rules will result in a manifest failure or miscarriage of justice, technicalities should be disregarded in order to resolve the case. In Aguam v. Court of Appeals,[27] we ruled that: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." "Law suits, 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.
	GR NO. 153721 2006-09-15	PHILIPPINE NATIONAL RAILWAYS v. MARIO RUSTIA CORONA, J.
In Fulgencio, et al. v. NLRC,[16] we refused to dismiss the case on the ground that petitioners did not explain why they failed to personally serve their petition on private respondents. There, we declared that technicalities should take a backseat to substantive rights, not the other way around.
	GR NO. 142937 2006-07-25	PHILIPPINE AMUSEMENT v. MARITA A. ANGARA AUSTRIA-MARTINEZ, J.
As a rule, a party who did not appeal from a decision of a court cannot obtain affirmative relief other than that granted in the appealed decision.[5] This applies also to decisions of administrative or quasi-judicial tribunals.[6] In the present case, however, while respondents did not appeal from CSC Resolution No. 991110 dated May 27, 1999 which merely ordered reinstatement and that they raised the issue of backwages only in the present motion, these did not preclude them from praying for the monetary benefits provided by law. Where an ironhanded application of the rules will result in an unmistakable failure or miscarriage of justice, technicalities should be disregarded in order to resolve the case.[7] This Court is, therefore, constrained to relax the rules to give way to the supreme and overriding interest of labor and justice. Indeed, 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.[8]
	GR NO. 142358 2006-01-31	GRAND PLACEMENT v. CA AUSTRIA-MARTINEZ, J.
The Court has often stressed that rules of procedure are merely tools designed to facilitate the attainment of justice. They were conceived and promulgated to effectively aid the court in the dispensation of justice. Courts are not slaves to or robots of technical rules, shorn of judicial discretion. In rendering justice, courts have always been, as they ought to be, conscientiously guided by the norm that on the balance, technicalities take a backseat against substantive rights, and not the other way around. Thus, if the application of the Rules would tend to frustrate rather than promote justice, it is always within our power to suspend the rules or except a particular case from its operation.[29]
	GR NO. 166429 2005-12-19	REPUBLIC v. HENRICK F. GINGOYON TINGA, J.
The disqualification of a judge is a deprivation of his/her judicial power[73] and should not be allowed on the basis of mere speculations and surmises. It certainly cannot be predicated on the adverse nature of the judge's rulings towards the movant for inhibition, especially if these rulings are in accord with law. Neither could inhibition be justified merely on the erroneous nature of the rulings of the judge. We emphasized in Webb v. People:[74]
	AM No. MTJ-99-1239 2005-07-29	VICENTE M. BATIC v. JUDGE VICTORIO L. GALAPON AZCUNA, J.
Technical rules must give way to substantive rights. As held in Roberto Fulgencio, et al. v. National Labor Relations Commission and Raycor Aircontrol Systems, Inc.,[5]
	GR NO. 157320 2005-06-28	KABANKALAN CATHOLIC COLLEGE v. KABANKALAN CATHOLIC COLLEGE UNION-PACIWU-TUCP PANGANIBAN, J.
Necessarily, the validity of the arbitral award became the law of the case between the parties. Under this legal principle, whatever is irrevocably established as the controlling legal rule or decision between the same parties in the same case continues to be the law of the case, so long as the facts on which the decision was predicated continues.[22] Otherwise stated, the principle holds that once an appellate court has declared the law in a case, that declaration continues to hold even in a subsequent appeal.[23] Reasons of public policy, judicial orderliness and economy require such stability in the final judgments of courts or tribunals of competent jurisdiction.[24]
	GR No. 138660 2004-02-05	HEIRS OF TRINIDAD DE LEON VDA. DE ROXAS v. CA CARPIO, J.
Well-settled is the rule that when a court of competent jurisdiction has tried and decided a right or fact, so long as the decision remains unreversed, it is conclusive on the parties and those in privity with them.[11] More so where the Supreme Court has already decided the issue since the Court is the final arbiter of all justiciable controversies properly brought before it.[12] As held in Buaya v. Stronghold Insurance Co., Inc.:[13]

ROBERTO FULGENCIO v. NLRC