http://www.lawphil.net/judjuris/juri2011/mar2011/gr_185758_2011.

html
Although the RTC has legal basis to order the dismissal of Civil Case No. 13-2007,
the Court finds this sanction too severe to be imposed on the petitioner where the
records of the case is devoid of evidence of willful or flagrant disregard of the rules
on mediation proceedings. There is no clear demonstration that the absence of
petitioners representative during mediation proceedings on March 1, 2008 was
intended to perpetuate delay in the litigation of the case. Neither is it indicative of
lack of interest on the part of petitioner to enter into a possible amicable settlement
of the case.
Unless the conduct of the party is so negligent, irresponsible, contumacious, or
dilatory as for non-appearance to provide substantial grounds for dismissal, the
courts should consider lesser sanctions which would still achieve the desired end.
Verily, the better and more prudent course of action in a judicial proceeding is to
hear both sides and decide the case on the merits instead of disposing the case by
technicalities. What should guide judicial action is the principle that a party-litigant
is to be given the fullest opportunity to establish the merits of his complaint or
defense rather than for him to lose life, liberty or property on technicalities.

Format for MR - http://attylaserna.blogspot.com/2009/12/doctrine-of-liberality-oftechnical.html