The Supreme Court held that strict adherence to procedural rules should not override the pursuit of justice, especially in criminal cases. The Court emphasized that an accused person should not be deprived of their liberty due to a lawyer’s negligence in complying with technical requirements. This ruling underscores the importance of ensuring that substantive justice prevails over mere procedural compliance, particularly when an individual’s freedom is at stake. By prioritizing a fair review of criminal convictions, the Court reaffirmed its commitment to protecting the rights of the accused and upholding the integrity of the judicial process.

Negligence vs. Justice: Can a Lawyer’s Mistake Cost You Your Freedom?

In Marlon Curammeng y Pablo v. People of the Philippines, the petitioner, a bus driver convicted of reckless imprudence resulting in homicide, faced a predicament. His appeal to the Court of Appeals (CA) was dismissed due to his counsel’s failure to attach a certification of non-forum shopping and other essential documents, as required by Rule 42 of the Rules of Court. The CA found Curammeng guilty beyond reasonable doubt, thus, he was sentenced to suffer the penalty of imprisonment for the indeterminate period of four (4) months and one (1) day of arresto mayor, as minimum, to four (4) years and two (2) months of prision correccional, as maximum, and ordered him to pay Franco’s heirs the amounts of P100,000.00 as civil indemnity and P200,000.00 as actual damages. The Supreme Court (SC) had to determine whether the CA correctly dismissed Curammeng’s petition based on these procedural deficiencies.

The Rules of Court are explicit about the requirements for a petition for review. Section 2 of Rule 42 mandates the inclusion of material portions of the record and a certification of non-forum shopping. This rule ensures that appellate courts have all the necessary information to make informed decisions. It also prevents litigants from simultaneously pursuing the same case in multiple forums. The rule states:

SEC. 2. Form and contents. –The petition shall be filed in seven (7) legible copies, with the original copy intended for the court being indicated as such by the petitioner, and shall (a) state the full names of the parties to the case, without impleading the lower courts or judges thereof either as petitioners or respondents; (b) indicate the specific material dates showing that it was filed on time; (c) set forth concisely a statement of the matters involved, the issues raised, the specification of errors of fact or law, or both, allegedly committed by the Regional Trial Court, and the reasons or arguments relied upon for the allowance of the appeal; (d) be accompanied by clearly legible duplicate originals or true copies of the judgments or final orders of both lower courts, certified correct by the clerk of court of the Regional Trial Court, the requisite number of plain copies thereof and of the pleadings and other material portions of the record as would support the allegations of the petition.

The petitioner shall also submit together with the petition a certification under oath that he has not theretofore commenced any other action involving the same issues in the Supreme Court, the Court of Appeals or different divisions thereof, or any other tribunal or agency; if there is such other action or proceeding, he must state the status of the same; and if he should thereafter learn that a similar action or proceeding has been filed or is pending before the Supreme Court, the Court of Appeals, or different divisions thereof, or any other tribunal or agency, he undertakes to promptly inform the aforesaid courts and other tribunal or agency thereof within five (5) days therefrom. (Emphases and underscoring supplied)

Traditionally, strict compliance with these rules is enforced because, as the Court noted, “the right to appeal is not a natural right or a part of due process; it is merely a statutory privilege, and may be exercised only in the manner and in accordance with the provisions of law.” Non-compliance, therefore, can lead to the dismissal of the appeal. However, the Supreme Court also recognized that rigid application of procedural rules can sometimes obstruct justice. In such instances, the Court may exercise its equity jurisdiction to relax these rules. The SC cited Heirs of Zaulda v. Zaulda, stating:

The reduction in the number of pending cases is laudable, but if it would be attained by precipitate, if not preposterous, application of technicalities, justice would not be served. The law abhors technicalities that impede the cause of justice. The court’s primary duty is to render or dispense justice. “It is a more prudent course of action for the court to excuse a technical lapse and afford the parties a review of the case on appeal 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 miscarriage of justice.“

What should guide judicial action is the principle that a party­ litigant should be given the fullest opportunity to establish the merits of his complaint or defense rather than for him to lose life, liberty, honor, or property on technicalities. The rules of procedure should be viewed as mere tools designed to facilitate the attainment of justice. Their strict and rigid application, which would result in technicalities that tend to frustrate rather than promote substantial justice, must always be eschewed.

In Curammeng’s case, the Supreme Court found that the dismissal of his appeal due to his counsel’s negligence was too harsh a penalty. Curammeng, a public utility vehicle driver and the sole breadwinner for his family, faced imprisonment based on a conviction that had not been fully reviewed. The SC underscored that the mistakes of counsel should not automatically bind the client, especially when it results in the deprivation of liberty. The Court acknowledged Curammeng’s counsel’s eventual compliance with the rules, albeit delayed, and emphasized the principle that an appeal in criminal cases opens the entire case for review. In these types of cases, the Supreme Court also takes into consideration mitigating circumstances.

Building on this principle, the Court highlighted the importance of affording Curammeng the opportunity to have his conviction fully reviewed. The Court noted that the nature of the offense and the potential consequences warranted a more lenient approach to procedural lapses. The Supreme Court held that the CA should have disregarded the procedural errors and proceeded with a thorough review of the factual and legal bases of Curammeng’s conviction. The Court emphasized that an appeal in criminal cases allows for a comprehensive examination of the entire case, including any errors that may not have been specifically raised by the parties.

This ruling underscores a critical balance in the Philippine legal system. While procedural rules are essential for maintaining order and efficiency in the courts, they should not be applied so rigidly as to cause injustice. The Supreme Court’s decision in Curammeng v. People reinforces the principle that substantive justice must prevail over technicalities, particularly when an individual’s liberty is at stake. This principle provides a safeguard against the potential for procedural errors to result in wrongful convictions. By prioritizing a fair and thorough review of criminal cases, the Court ensures that the rights of the accused are protected and that justice is served.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals correctly dismissed Curammeng’s appeal based on his counsel’s failure to comply with procedural rules regarding the attachment of a certification of non-forum shopping and other essential documents.
What is a certification of non-forum shopping?	A certification of non-forum shopping is a sworn statement affirming that the party has not filed any other action involving the same issues in other courts or tribunals. It aims to prevent litigants from pursuing simultaneous remedies in different venues.
Why did the Court of Appeals dismiss Curammeng’s appeal?	The Court of Appeals dismissed the appeal because Curammeng’s counsel failed to attach a certification of non-forum shopping and other material portions of the record, as required by Rule 42 of the Rules of Court.
On what grounds did the Supreme Court reverse the Court of Appeals’ decision?	The Supreme Court reversed the decision, holding that strict adherence to procedural rules should not override the pursuit of justice, especially in criminal cases where an individual’s liberty is at stake.
What is the significance of the Heirs of Zaulda v. Zaulda case cited in this decision?	The Heirs of Zaulda v. Zaulda case emphasizes that courts should prioritize dispensing justice over strict application of technicalities, and should excuse technical lapses to allow a review of the case on appeal rather than causing grave injustice.
What did the Supreme Court say about the mistakes of counsel in this case?	The Supreme Court noted that the mistakes of counsel should not automatically bind the client, especially when it results in the deprivation of liberty, and that a more lenient approach is warranted when the potential consequences are severe.
What is the effect of an appeal in criminal cases, according to the Supreme Court?	According to the Supreme Court, an appeal in criminal cases opens the entire case for review, allowing the appellate court to correct errors and revise the trial court’s judgment, even based on grounds not raised by the parties.
What was the final order of the Supreme Court in this case?	The Supreme Court granted the petition, reversed the Resolutions of the Court of Appeals, and remanded the case to the Court of Appeals for resolution of the appeal on its merits.

The Curammeng v. People case serves as a reminder that the pursuit of justice requires a balanced approach, where procedural rules are tools to facilitate, not obstruct, a fair and thorough examination of the merits of a case. This decision reinforces the judiciary’s role in safeguarding individual liberties and ensuring that justice prevails, even in the face of procedural imperfections.

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: MARLON CURAMMENG Y PABLO v. PEOPLE OF THE PHILIPPINES, G.R. No. 219510, November 14, 2016