Wednesday, May 27, 2026

Assignment of errors on appeal: a matter not raised by the parties may be reviewed if necessary for a complete resolution of the case.

EN BANC
[ G.R. No. 242957. February 28, 2023 ]

THE BOARD OF COMMISSIONERS OF THE BUREAU OF IMMIGRATION AND THE JAIL WARDEN, BUREAU OF IMMIGRATION DETENTION CENTER, PETITIONERS, VS. YUAN WENLE, RESPONDENT.

https://lawphil.net/judjuris/juri2023/feb2023/gr_242957_2023.html?utm_source=chatgpt.com

"Nonetheless, a matter not raised by the parties may be reviewed if necessary for a complete resolution of the case;66 as this Court is imbued with sufficient authority and discretion to do so.67 The following instances include: (1) grounds not assigned as errors but affecting jurisdiction over the subject matter; (2) matters not assigned as errors on appeal but are evidently plain or clerical errors within contemplation of law; (3) matters not assigned as errors on appeal but consideration of which is necessary in arriving at a just decision and complete resolution of the case or to serve the interests of justice or to avoid dispensing piecemeal justice; (4) matters not specifically assigned as errors on appeal but raised in the trial court and are matters of record having some bearing on the issue submitted which the parties failed to raise or which the lower court ignored; (5) matters not assigned as errors on appeal but closely related to an error assigned; and (6) matters not assigned as errors on appeal but upon which the determination of a question properly assigned, is dependent.68

Here, it appears that both parties do not dispute the constitutional validity of warrants issued by administrative bodies – specifically the Bureau of Immigration. What they are arguing instead is whether SDOs violate a foreign detainee's right to due process. However, a closer look at this issue will reveal that the same cannot be meaningfully resolved without passing upon the constitutional validity of administrative warrants."