Circular 28-91 deletes docket no. requirement in review petitions' captions before SC or CA

Even assuming arguendo that there was no substantial compliance with Circular 28-91, the dismissal was still unwarranted considering that the petition for review before the CA was filed after said Circular was revised on April 1, 1994. The revised version deleted the requirement that the docket number of the case before the lower court whose ruling is sought to be reviewed must be set out in the caption of the petition filed with the SC or CA. [G.R1. No. 121488. November 21, 1996]