GENERAL PRINCIPLES

BERNABE vs. ALEJO

A VESTED RIGHT is defined as “one which is absolute, complete and unconditional, to the exercise of which no obstacle exists, and
which is immediate and perfect in itself and not dependent upon a contingency.” Respondent however contends that the filing of an
action for recognition is procedural in nature and that “as a general rule, no vested right may attach to [or] arise from procedural laws.”

SUBSTANTIVE LAW creates SUBSTANTIVE RIGHTS and the two terms in this respect may be said to be synonymous.
SUBSTANTIVE RIGHTS is a term which includes those rights which one enjoys under the legal system prior to the disturbance of
normal relations. SUBSTANTIVE LAW is that part of the law which creates, defines and regulates rights, or which regulates the rights
and duties which give rise to a cause of action; that part of the law which courts are established to administer; as opposed to adjective
or remedial law, which prescribes the method of enforcing rights or obtains redress for their invasion.

In determining whether a rule prescribed by the Supreme Court, for the practice and procedure of the lower courts, abridges, enlarges,
or modifies any substantive right, the test is whether the rule really regulates procedure, that is, the judicial process for enforcing rights
and duties recognized by substantive law and for justly administering remedy and redress for a disregard or infraction of them. If the
rule takes away a vested right, it is not procedural. If the rule creates a right such as the right to appeal, it may be classified as a
substantive matter; but if it operates as a means of implementing an existing right then the rule deals merely with procedure.

BERGONIA and CASTILLO vs. COURT OF APPEALS

Procedural rules are tools designed to facilitate the adjudication of cases. Courts and litigants alike are, thus, enjoined to abide strictly
by the rules. And while the Court, in some instances, allows a relaxation in the application of the rules, this was never intended to
forge a bastion for erring litigants to violate the rules with impunity. The liberality in the interpretation and application of the rules
applies only in proper cases and under justifiable causes and circumstances. While it is true that litigation is not a game of
technicalities, it is equally true that every case must be prosecuted in accordance with the prescribed procedure to insure an orderly
and speedy administration of justice.

The right to appeal is a statutory right and the party who seeks to avail of the same must comply with the requirements of the Rules.
Failing to do so, the right to appeal is lost.

BPI vs. COURT OF APPEALS

It is settled that liberal construction of the rules may be invoked in situations where there may be some excusable formal deficiency
or error in a pleading, provided that the same does not subvert the essence of the proceeding and connotes at least a reasonable
attempt at compliance with the rules. After all, rules of procedure are not to be applied in a very rigid, technical sense; they are
used only to help secure substantial justice.

CMTC vs. BHAGIS INTERNATIONAL

Where strong considerations of substantive justice are manifest in the petition, the strict application of the rules of procedure may be
relaxed, in the exercise of its equity jurisdiction. Thus, a rigid application of the rules of procedure will not be entertained if it will
obstruct rather than serve the broader interests of justice in the light of the prevailing circumstances in the case under consideration.

The rule, which states that the mistakes of counsel binds the client, may not be strictly followed where observance of it would result
in outright deprivation of the client’s liberty or property, or where the interest of justice so requires. In rendering justice, procedural
infirmities take a backseat against substantive rights of litigants. Corollarily, if the strict application of the rules would tend to frustrate
rather than promote justice, this Court is not without power to exercise its judicial discretion in relaxing the rules of procedure.