The Supreme Court ruled that the belated submission of a Barangay Council Resolution and a Certification and Verification of Non-Forum Shopping constitutes substantial compliance with procedural requirements. This decision underscores that strict adherence to procedural rules should not overshadow the pursuit of substantive justice, particularly when dealing with boundary disputes between local government units.

Boundary Disputes and Belated Filings: Can Substantial Compliance Save the Day?

This case revolves around a boundary dispute between Ormoc City and the Municipality of Kananga, which was initially settled through an Amicable Settlement. Barangay Tongonan, feeling aggrieved by the settlement’s impact on its territory, sought to annul the agreement. The Court of Appeals (CA) dismissed Barangay Tongonan’s petition due to procedural defects, specifically concerning the verification and certification requirements. The central legal question is whether the subsequent submission of corrected documents constitutes substantial compliance, thereby warranting a review of the case on its merits.

The CA initially dismissed the amended petition due to three key reasons: the lack of the original Barangay Council Resolution authorizing the Punong Barangay to sign the Verification and Certification Against Non-Forum Shopping, insufficient evidence of the representative’s identity, and the fact that the Verification and Certification were subscribed before an Assistant Provincial Prosecutor. These issues, according to the CA, rendered the petition fatally defective. However, the Supreme Court disagreed, emphasizing that procedural rules should not be applied so rigidly as to defeat the ends of justice.

The Court acknowledged the importance of verifying petitions and submitting a sworn certification of non-forum shopping, as required by Rule 47, Section 4 of the Rules of Court. However, it also recognized that strict adherence to these requirements is not always necessary, especially when there has been substantial compliance. The Court pointed out that the CA itself had initially reinstated the amended petition, indicating an earlier leniency towards procedural imperfections.

Building on this, the Supreme Court noted that the amended petition was, in fact, accompanied by a certified true copy of the Barangay Resolution authorizing the Punong Barangay to file the petition. While the initial submission lacked explicit authorization for the Punong Barangay to execute the Certification and Verification of Non-forum shopping, this defect was later addressed. The Court then addressed the main issue of whether the submission of corrected documents and a new Barangay Council Resolution cured the initial defect.

The Court turned to established jurisprudence regarding non-compliance with verification and certification requirements, outlining a set of guidelines. These guidelines distinguish between defects in verification and those in certification against forum shopping. While defects in verification may be excused if the pleading is made in good faith, non-compliance with certification is generally not curable unless there is “substantial compliance” or “special circumstances or compelling reasons.”

Drawing from previous cases such as Mediserv, Inc. v. Court of Appeals, et al. and Uy v. Land Bank of the Philippines, the Court highlighted instances where belated filings of certifications were deemed sufficient for substantial compliance. In Mediserv, the failure to submit proof of a representative’s authority was rectified by subsequent submission of the required document. Similarly, in Uy, a petition was reinstated even though the verification and certification were submitted after the initial dismissal. These cases demonstrated a willingness to prioritize substance over form when justice so requires.

In the present case, the Court found that the submission of the original Barangay Council Resolution authorizing the succeeding Punong Barangay to file the amended petition, along with a new certification, constituted substantial compliance. The Court reasoned that the change in leadership necessitated a new resolution, and the delay in submission should not prejudice the Barangay’s right to have its case heard. Moreover, the court articulated that resolving the boundary dispute on its merits served the ends of substantive justice more effectively than dismissing the case on a procedural technicality. The underlying principle here is that procedural rules are tools to facilitate justice, not barriers to it.

The Supreme Court also cited Fernandez v. Villegas, emphasizing that rules on forum shopping, like those on verification, are designed to promote the orderly administration of justice and should not be interpreted in a way that undermines their objectives. Substantial compliance is permissible under justifiable circumstances, indicating a flexible approach to procedural rules.

FAQs

What was the key issue in this case?	The central issue was whether the belated submission of a Barangay Council Resolution and a Certification and Verification of Non-Forum Shopping constitutes substantial compliance with procedural requirements in an annulment case.
What is a Certification of Non-Forum Shopping?	A Certification of Non-Forum Shopping is a sworn statement confirming that the party has not filed any other action involving the same issues in any other court or tribunal. It aims to prevent the simultaneous pursuit of multiple cases on the same subject matter.
What does ‘substantial compliance’ mean in this context?	‘Substantial compliance’ means that the party has generally met the essential requirements of the rule, even if there are minor deviations or omissions. The key is whether the overall purpose of the rule has been achieved.
Why did the Court of Appeals initially dismiss the petition?	The Court of Appeals dismissed the petition due to procedural defects, including the lack of the original Barangay Council Resolution authorizing the filing of the petition and issues with the verification and certification documents.
How did the Supreme Court justify its decision?	The Supreme Court justified its decision by emphasizing that procedural rules should not be applied so rigidly as to defeat the ends of justice, especially when there has been substantial compliance with the rules.
What is the significance of a Barangay Council Resolution?	A Barangay Council Resolution is a formal decision by the Barangay Council authorizing a specific action, such as filing a legal petition. It demonstrates that the action is supported by the local government unit.
What happens next in this case?	The case is reinstated and remanded to the Court of Appeals for proper disposition. This means the Court of Appeals will now consider the merits of the case, rather than dismissing it on procedural grounds.
Can this ruling be applied to other types of cases?	Yes, the principle of substantial compliance can be applied to other types of cases where there are minor procedural defects, provided that the essential requirements of the rules have been met and the ends of justice are served.

This case reinforces the principle that procedural rules are intended to facilitate justice, not obstruct it. The Supreme Court’s decision allows for flexibility in applying these rules, particularly when substantial compliance has been achieved. This ensures that cases are decided on their merits, rather than being dismissed on technicalities.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: BARANGAY TONGONAN V. BUAYA, G.R. No. 204183, June 20, 2018