WHETHER THE CA ERRED IN DISMISSING THE PETITION FOR

TECHNICALITIES
CHONA JAYME, VS. PETITIONER, NOEL JAYME AND THE PEOPLE OF THE
PHILIPPINES, RESPONDENTS
G.R. No. 248827, August 27, 2020 REYES, J. JR., J.
DOCTRINE:
Well-entrenched is the rule that the Court may relax the strict application of the rules of
procedure in the exercise of its equity jurisdiction if its rigid application will tend to obstruct
rather than serve the broader interests of justice.22 Until then, the procedural rules are accorded
utmost respect and due regard as they are designed to facilitate the adjudication of cases to
remedy the worsening problem of delay in the resolution of rival claims and in the administration
of justice.23 The relaxation of the strict application of the rules may only be allowed if it would
accommodate the greater interest of justice in light of the prevailing circumstances of the case,
such as where strong considerations of substantive justice are manifest in the petition.
FACTS:
Respondent initiated a case for Falsification of Public Document under Article 172 par. 1
in relation to Article 171 par. 1 and 2 of the Revised Penal Code for causing it to appear that her
deceased husband signed the Deed of Absolute Sale by counterfeiting or imitating his signature
in the said document. The deed of sale involved a subject property which was sold to them by a
certain Chona Jayme to allow the property to be mortgaged in favor of a loan made Elisa.
The Regional Trial Court convicted her of the crime she was charged with. Likewise the
Municipal Trial Courts in Cities convicted her of the crime. The decision was also affirmed by
the Regional Trial Court. The Court of Appeals also affirmed the decision of the lower courts. It
also dismissed the motion for reconsideration because of the following reasons;
(1) being filed out of time;
(2) failure to comply with the requirements as to the contents of the petition; and
(3) failure to pay the docket and other lawful fees.
The Motion for Reconsideration was then again denied hence this petition.

ISSUE:
Did the Court of Appeals err in dismissing the case because of mere technicalities?
RULING:
Yes. The Court agrees with the CA's stringent application of the procedural rules.
Petitioner's failure to perfect an appeal within the prescribed reglementary period is not a mere
technicality, but jurisdictional. Her failure to meet the requirements of an appeal deprives the
appellate court of jurisdiction to entertain any appeal. Furthermore, factual issues are beyond the
scope of a Rule 45 petition as it is not our function to analyze or weigh all over again evidence
already considered in the proceedings below. While there are recognized exceptions to this rule,
not one is applicable in the instant petition.
Well-entrenched is the rule that the Court may relax the strict application of the rules of
procedure in the exercise of its equity jurisdiction if its rigid application will tend to obstruct
rather than serve the broader interests of justice.22 Until then, the procedural rules are accorded
utmost respect and due regard as they are designed to facilitate the adjudication of cases to
remedy the worsening problem of delay in the resolution of rival claims and in the administration
of justice.23 The relaxation of the strict application of the rules may only be allowed if it would
accommodate the greater interest of justice in light of the prevailing circumstances of the case,
such as where strong considerations of substantive justice are manifest in the petition.
 WHETHER OR NOT THE COURT OF APPEALS CORRECTLY DISMISSED THE
PETITION FOR HAVING BEEN FILED OUT OF TIME
ROGER V. CHIN, PETITIONER, VS. MAERSK-FILIPINAS CREWING, INC.,
MAERSK LINE A/S, AND RENEL C. RAMOS, RESPONDENTS
G.R. No. 247338, September 02, 2020 PERLAS-BERNABE, J.
DOCTRINE:
In the exercise of its power to promulgate implementing rules and regulations, an
implementing agency, such as the Department of Labor, is restricted from going beyond the
terms of the law it seeks to implement; it should neither modify nor improve the law. The agency
formulating the rules and guidelines cannot exceed the statutory authority granted to it by the
legislature.
FACTS:
Petitioner was hired as Able Seaman by Maersk-Filipinas Crewing, Inc. and its officer Renel C.
Ramos, for and on behalf of their foreign principal, Maersk Line A/S (respondents), for a six (6)-
month contract on board the vessel MV Maersk Danube, allegedly covered by a Singaporean
Organization of Seamen Collective Bargaining Agreement (SoS CBA). After undergoing the
required Pre-Employment Medical Examination, petitioner was declared fit for duty so he
boarded the vessel and assumed his duties and was required manual labor. while lifting the steel
cover of a chain pipe located under the mooring in order to clear some debris, petitioner
allegedly felt excruciating pain on his back that resulted to blurring of vision or symptoms of
heart attack. He reported his condition to his superiors and requested for medical consultation,
but was refused. Instead, he was recommended for medical repatriation and, subsequently,
signed off from the vessel
Upon examination he was diagnosed to be suffering from Degenerative Disc Disease.
After completing various consultations and tests petitioner was revealed to be asymptomatic and
had no lower back pains and thus, he was declared fit to work and signed a Certificate of Fitness
for Work. On his second medical examination, he was diagnosed to be unfit for sea duty in
whatever capacity. Petitioner requested disability compensation from respondents, which was
denied, prompting him to file a notice to arbitrate with the National Conciliation and Mediation
Board (NCMB) for permanent and total disability benefits, damages, and attorney's fees. The
parties agreed to undergo Voluntary Arbitration but dismissed the complaint for lack of merit.
Upon Petition for Review under Rule 43 of the Rules of Court, the Court of Appeals
dismissed the petition outright fore being filed one (1) day late.
ISSUE:
Did the Court of Appeals err in dismissing the case for being filed out of time?
RULING:
 Yes. In the 2010 ruling in Teng v. Pagahac, the Court clarified that the 10-day period set
in Article 276 of the Labor Code gave the aggrieved parties the opportunity to file their motion
for reconsideration, which was more in keeping with the principle of exhaustion of
administrative remedies, holding thusly:

In the exercise of its power to promulgate implementing rules and regulations, an

implementing agency, such as the Department of Labor, is restricted from going beyond the
terms of the law it seeks to implement; it should neither modify nor improve the law. The agency
formulating the rules and guidelines cannot exceed the statutory authority granted to it by the
legislature.

By allowing a 10-day period, the obvious intent of Congress in amending Article 263 to
Article 262-A is to provide an opportunity for the party adversely affected by the VA's decision
to seek recourse via a motion for reconsideration or a petition for review under Rule 43 of the
Rules of Court filed with the CA. Indeed, a motion for reconsideration is the more appropriate
remedy in line with the doctrine of exhaustion of administrative remedies. For this reason, an
appeal from administrative agencies to the CA via Rule 43 of the Rules of Court requires
exhaustion of available remedies as a condition precedent to a petition under that Rule.

The petition was granted and the Court of Appeals decision was set aside.