Substantial compliance with docket number, caption requirements

The petition for review does not state the docket numbers in the caption nor anywhere in the body of the petition. However, the decisions of both lower courts which mentioned said docket numbers were attached and made an integral part if the petition. This fact, together with petitioner's subsequent compliance by stating those numbers in their motion for reconsideration, should have been considered by the CA. As previously held by this court, if the docket numbers of the case before the lower court were not indicated in the caption but were set out in the body of the petition, there is substantial compliance with Cir. 28-91. Instead of dismissing the petition, the CA could and should have merely required petitioners to strictly comply with Circular 28-91 by amending the caption. [G.R. No. 121488. November 21, 1996]