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	GR NO. 168943 2006-10-27	IGLESIA NI CRISTO v. THELMA A. PONFERRADA CALLEJO, SR., J.
On April 7, 2005, the CA rendered the assailed decision[17] dismissing the petition, holding that the RTC did not commit grave abuse of its discretion amounting to lack or excess of jurisdiction in denying petitioner's motion to dismiss. As the Court held in DAR v. Alonzo-Legasto[18] and in Gudoy v. Guadalquiver,[19] the certification signed by one with respect to a property over which he shares a common interest with the rest of the plaintiffs (respondents herein) substantially complied with the Rules. As to the issue of prescription, the appellate court held that the prescriptive period should be reckoned from 1996, when petitioner claimed ownership and barred respondents from fencing the property.
	GR NO. 154410 2005-10-20	HEAVYLIFT MANILA v. CA QUISUMBING, J.
The rule on certification against forum-shopping requires strict compliance. The requirement underscores its mandatory nature such that it cannot be altogether dispensed with. However, under justifiable circumstances, the Court does allow substantial compliance.[16]