GR 149634; (July, 2004) (Digest)
G.R. No. 149634 ; July 6, 2004
LORETA TORRES, ET AL., petitioners, vs. SPECIALIZED PACKAGING DEVELOPMENT CORPORATION, ET AL., respondents.
FACTS
Petitioners, claiming to be employees of respondent Specialized Packaging Development Corporation (SPDC), filed complaints for illegal dismissal and monetary claims. The Labor Arbiter ruled in their favor, but the National Labor Relations Commission (NLRC) reversed this decision. Petitioners then filed a Petition for Certiorari with the Court of Appeals (CA). The CA dismissed the petition outright due to a procedural defect. The verification and certification against forum shopping attached to the petition were signed by only two (Evelyn Dolom and Criselina Anquilo) out of the twenty-five petitioners. The appellate court held this was a fatal defect, as the duty to verify and certify is strictly addressed to all principal petitioners to effectively prevent forum shopping.
ISSUE
Whether the Court of Appeals erred in dismissing the petition for certiorari based solely on the defective verification and certification against forum shopping.
RULING
Yes, the Court of Appeals erred. The Supreme Court reversed the CA’s resolutions and reinstated the petition. The Court held that while procedural rules require strict compliance, they may be relaxed for compelling reasons to serve substantial justice. The outright dismissal of the petition would seriously impair the orderly administration of justice, as it would bar a review of the substantive merits of the labor case. The Court found justifiable cause for the procedural lapse. The petitioners were numerous, indigent workers residing in different provinces, making it difficult to procure all signatures. More importantly, the two signatories sufficiently represented the interests of all co-petitioners, as they were parties to the same consolidated cases with a common cause of action and prayer for relief. The certification executed by them substantially complied with the rule’s objective to prevent forum shopping, as any ruling would bind all petitioners. The Court emphasized that technicalities should not frustrate the resolution of cases on their merits, especially in labor disputes where the constitutional policy is to afford protection to labor. The case was remanded to the CA for proper proceedings on the substantive issues.