Verification requirement; sufficient knowledge rule

In Delfino, Sr. v. Anasao, the Supreme Court held that the verification requirement is deemed substantially complied with even when only one of the plaintiff-heirs, who had sufficient knowledge and belief to swear to the truth of the allegations in the petition, signed the verification attached to it. The same liberality was likewise applied to the certification against forum shopping when the Court allowed the signature of only one of the petitioners because of the commonality of interest of all the parties with respect to the subject of the controversy. (G.R. No. 197486, 10 September 2014, citing Iglesia ni Cristo v. Judge Ponferrada 563 Phil.705, 2006)