4/14/2021 E-Library - Information At Your Fingertips: Printer Friendly The Court will now discuss the propriety of the CA's dismissal of the petition for certiorari. Substantial compliance with the formal requirements of a petition for certiorari. To reiterate, among the grounds relied upon by the CA in dismissing petitioner's petition for certiorari were: (1) petitioner failed to attach a certified true copy of the RTC Decision dated July 21, 2016 and the attached copy merely bore the notation "ORIGINAL SIGNED;" (2) the RTC Decision dated March 20, 2014 attached to the petition was an illegible photocopy; and (3) copies of pertinent pleadings/documents and other relevant portions of the records, such as the opposition to the motion for reconsideration, reply, writ of execution, among others, were not attached as annexes to the petition. In Jaro v. Court of Appeals,[33] the Court ruled that while rules of procedure are essential to the proper, efficient and orderly dispensation of justice, such rules are to be applied in a manner that will help secure and not defeat justice.[34] Thus, the Court has ruled against the dismissed of appeals based solely on technicalities, especially so when the appellant had substantially complied with the formal requirements.[35] Specifically, the Court ruled that subsequent and substantial compliance may call for the relaxation of procedural rules;[36] thus: In Cusi-Hernandez vs. Diaz and Piglas-Kamao vs. National Labor Relations Commission, we ruled that the subsequent submission of the missing documents with the motion for reconsideration amounts to substantial compliance. The reasons behind the failure of the petitioners in these two cases to comply with the required attachments were no longer scrutinized. What we found noteworthy in each case was the fact that the petitioners therein substantially complied with the formal requirements. We ordered the remand of the petitions in these cases to the Court of Appeals, stressing the ruling that by precipitately dismissing the petitions "the appellate court clearly put a premium on technicalities at the expense of a just resolution of the case."[37] (Emphasis supplied; citations omitted.) The documents required to be attached in a petition for certiorari that is filed before the CA, such as the instant case, are found under Section 3, Rule 46 and Section 1, Rule 65 of the Rules of Court. As explained by the Court in Republic v. Carmel Dev't. Inc.,[38] Rule 46 primarily governs original actions for certiorari filed in the CA, but Rule 65 generally serves to supplement it.[39] Specifically, Section 2,[40] Rule 46 expressly states that Rule 46 shall apply to original actions for certiorari, and that except as otherwise provided in Rule 46, the actions for certiorari shall be governed by Rule 65. [41] As such, Rules 46 and 65 co-exist with each other and should be construed so as to give effect to every provision of both rules.[42] Section 3, Rule 46 provides: https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66374 4/16