The Supreme Court is always guided by the principle that rules
shall be liberally construed in order to promote their objective of securing a
just, speedy and inexpensive disposition of every action and
proceeding.[1] Simply put, rules of procedure should facilitate an
orderly administration of justice. They should not be strictly applied causing
injury to a substantive right of a party to case. This precept has been
elucidated by the Supreme Court in De Guzman v. Sandiganbayan[2] to wit:
[T]he 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 avoided. Even the Rules of Court envision this liberality. This power to suspend or even disregard the rules can be so pervasive and encompassing so as to alter even that which this Court itself has already declared to be final.
ALSO READ: People v. Sergio, G.R. No. 240053, October 09, 2019.
There are several instances wherein the Court has relaxed procedural rules to
serve substantial justice because of any of the following reasons: (a) matters
of life, liberty, honor or property; (b) the existence of special or
compelling circumstances, (c) the merits of the case, (d) a cause not entirely
attributable to the fault or negligence of the party favored by the suspension
of the rules, (e) a lack of any showing that the review sought is merely
frivolous and dilatory, and (t) the other party will not be unjustly
prejudiced thereby.[3]
Nonetheless, the Court always reminds party
litigants that bare invocation of "the interest of substantial justice" is not
a magic phrase that will automatically oblige the Court to suspend procedural
rules. To stress, "[procedural rules are not to be belittled or dismissed
simply because their non-observance may have prejudiced a party's substantive
rights. Like all rules, they are required to be followed except only for the
most persuasive of reasons when they may be relaxed to relieve a litigant of
an injustice not commensurate with the degree of his thoughtlessness in not
complying with the procedure prescribed."[4]
[1] Rules of Court, Rule 1, Section 6.
[2] 326 Phil. 182, 190 (1996).
[3] Malixi v.Baltazar, G.R. No. 208224, November 22, 2017, 846 SCRA 244, 272, citing Barnes v. Hon. Quijano Padilla, 500 Phil. 303, 311 (2005); Sanchez v. Court of Appeals, 452 Phil. 665, 674 (2003).
[4] Philippine Savings Bank v. Papa, G.R. No. 200469, January 15, 2018, citing Lazaro v. Court of Appeals, 386 Phil. 412,417(2000).