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Benguet Corp V Cotdillera Caraballo Mission, Inc 469 SCRA 381

Benguet Corporation filed a forcible entry complaint against Cordillera Caraballo Mission, Inc. due to unauthorized construction on its mineral claim, but the case was dismissed by the RTC for lack of proper documentation. The Supreme Court upheld this dismissal, stating that failure to attach essential documents like a board resolution is not an excusable mistake and affects procedural integrity. The Court emphasized that while procedural requirements are generally formal and non-jurisdictional, compliance with essential requirements is necessary to avoid dismissal.

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Aires Mia Amor Rodriguez
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32 views1 page

Benguet Corp V Cotdillera Caraballo Mission, Inc 469 SCRA 381

Benguet Corporation filed a forcible entry complaint against Cordillera Caraballo Mission, Inc. due to unauthorized construction on its mineral claim, but the case was dismissed by the RTC for lack of proper documentation. The Supreme Court upheld this dismissal, stating that failure to attach essential documents like a board resolution is not an excusable mistake and affects procedural integrity. The Court emphasized that while procedural requirements are generally formal and non-jurisdictional, compliance with essential requirements is necessary to avoid dismissal.

Uploaded by

Aires Mia Amor Rodriguez
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

Benguet Corp v Cotdillera Caraballo Mission, Inc 469 SCRA 381

Key Facts:
Benguet Corporation filed a forcible entry complaint against
Cordillera Caraballo Mission, Inc. (CCMI) after discovering
unauthorized construction activities on its mineral claim. The MTC
ruled in favor of Benguet, but the RTC reversed and dismissed the
case for failure to state a cause of action. The Court of Appeals
dismissed the petition for procedural reasons, notably the absence
of a board resolution and certified pleadings. The Supreme Court
upheld the dismissal, emphasizing procedural compliance.

Issue & Ruling:


The issue was whether the failure to attach the board resolution
and other pleadings was an excusable mistake.
The Supreme Court ruled it was not, affirming that verification
requirements are formal and not jurisdictional. Non-compliance
does not necessarily invalidate pleadings if substantial
compliance is shown.

Reasoning of the SC:


The Court clarified that verification is a formal requirement aimed
at ensuring truthfulness and preventing forum-shopping, not a
jurisdictional defect. Since the petitioner’s affiant’s authority was
later ratified by the board, the omission was considered an
excusable mistake. The Court emphasized liberal application of
procedural rules to promote substantial justice, but procedural
lapses that affect essential requirements, like attaching the
proper resolution, are not excusable.

Doctrine:
The Court reaffirmed that procedural requirements are generally
formal and non-jurisdictional; non-compliance does not
automatically invalidate pleadings if substantial justice is served.
However, failure to attach essential documents like a board
resolution, which affects procedural integrity, is not an excusable
mistake and can justify dismissal.

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