Substantive Justice over Procedural Rules

PROBLEM:
The CA dismissed the petition outright for procedural defects namely: 1. Remedy
should be a petition under Rule 43 instead of Rule 65, 2. Filing a second Motion for
Reconsideration, which is a prohibited appeal, and 3. Nonpayment of docket fees. The
CA found that Agrarian Reform Adjudicator Ancheta, who was found guilty by the
Ombudsman of Simple Neglect of Duty by neglecting to tear the printed unofficial order,
failed to state the date of the receipt of the assailed decision for his filing of the
prohibited second MR.
Is the CA correct in dismissing outright the petition, due to failure to comply with
procedural rules?
ANSWER:
NO. Compliance with procedural rules is necessary for an orderly administration of
justice but these rules are not to be rigidly applied to frustrate the greater interest of
substantive justice.
1. Rule 65 was the correct remedy based on Republic v Francisco which ruled that
decisions of administrative agencies declared by law as final and unappealable
are subject to judicial review. The decision of the Ombudsman may be reviewed
via petition for certiorari under Rule 65.

2. Failure to state the date of the decision on the MR while indeed a procedural
irregularity does not warrant a dismissal of the petition.

3. Ancheta already paid the correct docket fees.

The petition is meritorious. Litigations should, as much as possible, be decided on

the merits and not on technicalities. (Ancheta vs. Villa, G.R. No. 229634, 2020)