The Supreme Court held that when co-owners with a shared interest in a property file a case, the signature of only one co-owner on the certification against forum shopping constitutes substantial compliance. This means the case should not be dismissed based on a technicality. The decision protects the rights of co-owners to pursue legal action concerning their shared property, ensuring that minor procedural errors do not prevent the resolution of substantive issues.

One Signature Enough? Co-Owners, Shared Interests, and Forum Shopping Rules

This case revolves around a dispute over land ownership in Panabo City, Davao del Norte. Spouses Gavino and Violeta Gudoy, along with Lillette Gudoy, Ninoleta Gudoy, Joel Tolentino, Amarylis Bisnar, Roldan Bustamante, Welando Ellazo, and Anna Socorro Gudoy (collectively, the petitioners), filed a complaint against Jacinta and Adriano Guadalquiver (the respondents) to quiet title and claim damages. The core issue arose because only Gavino Gudoy signed the verification and certification against forum shopping attached to the complaint. Forum shopping, in simple terms, is when a party tries to file the same case in different courts to get a favorable decision.

The Regional Trial Court (RTC) initially dismissed the case based on the argument that all plaintiffs should have signed the certification, asserting that only Gavino Gudoy could not possibly know if the other eight plaintiffs had filed similar cases elsewhere. This decision was appealed, leading to the Supreme Court’s review. The petitioners argued that since they are co-owners of the property in question, the signature of one co-owner suffices, relying on the principle of substantial compliance. They also contended that the trial court was estopped from raising the issue after previously taking actions related to the case.

The Supreme Court reversed the RTC’s decision, holding that substantial compliance was met in this instance. The Court acknowledged that Supreme Court Circular No. 28-91, as amended by SC Administrative Circular No. 4-94, typically requires all plaintiffs to sign the certification against non-forum shopping. The purpose of this rule is to prevent litigants from simultaneously pursuing the same claim in different courts or tribunals. The Court distinguished this case from Loquias v. Office of the Ombudsman, where individual defendants were being sued in their personal capacities, necessitating individual certifications.

Here, the petitioners, as co-owners pro indiviso of the land, possess a joint interest in the property as demonstrated by Transfer Certificate of Title No. C-7700. This shared interest is a crucial factor, because, as the Court stated, “As owners in common, none of the said petitioners is entitled to any specific portion of the said property as they all have a joint interest in the undivided whole.” The Supreme Court pointed to the case of Dar v. Alonzo-Legasto as instructive. That case involved a complaint against multiple spouses. The Court reasoned that, under the system of absolute community of property, one spouse’s signature on the certification was sufficient to meet the requirements.

The rule of substantial compliance may be availed of… it merely underscores its mandatory nature in that it cannot be altogether dispensed with or its requirements completely disregarded but it does not thereby prevent substantial compliance on this aspect of its provisions under justifiable circumstances.

This approach prioritizes justice over strict adherence to formal rules. This is because enforcing literal compliance in this context could cause “a palpable denial of substantial justice to petitioners”. The Court underscored that the circular on non-forum shopping is designed to promote the orderly administration of justice, not to create technical barriers that prevent the resolution of legitimate claims. The decision emphasizes that while the rule on certification against forum shopping is mandatory, substantial compliance may suffice under certain circumstances, particularly when co-owners with shared interests are involved. This ruling reinforces the principle that courts should prioritize substance over form to ensure a fair and just resolution of disputes.

FAQs

What was the key issue in this case?	Whether the complaint should be dismissed because only one of the nine co-owners signed the certification against forum shopping.
What is a certification against forum shopping?	A sworn statement attached to a complaint affirming that the plaintiff has not filed similar cases in other courts.
What does “substantial compliance” mean in this context?	It means that despite a technical defect (not all co-owners signed), the purpose of the rule was still met.
Who are considered co-owners pro indiviso?	Individuals who jointly own a property where no specific portion belongs exclusively to any one owner.
Why did the Supreme Court reverse the lower court’s decision?	Because all the plaintiffs share a common interest in the property as co-owners and one signature sufficed.
What was the basis for the trial court’s dismissal of the case?	The trial court required that all plaintiffs must sign the Certification against Anti-Forum Shopping.
Is this case applicable to situations other than co-ownership?	The court explicitly stated it applied to peculiar circumstances, such as where co-parties are being sued in their individual capacities.
What is the practical effect of this ruling?	It prevents dismissal of cases on a mere technicality that serves no ultimate purpose.

This case illustrates the importance of balancing procedural rules with the pursuit of justice. By allowing for substantial compliance in certain circumstances, the Supreme Court ensured that legitimate claims are not dismissed due to minor technical defects. It reinforces the principle that courts should look beyond form and focus on substance to achieve fair outcomes in legal disputes.

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: Gudoy, et al. vs. Guadalquiver, et al., G.R. No. 151136, May 27, 2004