This case has been cited 2 times or more.
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2007-08-02 |
AZCUNA, J. |
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| Furthermore, petitioner contends that she submitted the certification against forum shopping on May 3, 1994, barely a week from the time the complaint was filed. In Kavinta v. Castillo, Jr.,[8] this Court held that "[t]he proximity of the filing of the complaint to the date of the effectivity of Administrative Circular No. 04-94 may be pleaded as a justifying circumstance, and the belated filing of the certification required thereunder may be deemed a substantial compliance therewith." | |||||