GR 214249; (September, 2017) (Digest)
G.R. No. 214249 . September 25, 2017.
HENRY E. YU, ET AL., PETITIONERS, VS. SR METALS, INC. (SRMI), ELOISA E. SEGARRA, FRANCIS ERIC GUTIERREZ, JIMWELL ORPILLA AND GODOFREDO NARDO, RESPONDENTS.
FACTS
The petitioners were employees of respondent SR Metals, Inc. (SRMI), a mining company in Agusan del Norte. From 2008 to 2010, they were terminated from their employment and subsequently replaced by workers from Asiapro Cooperative. The petitioners, in fifteen separate groups, filed complaints for illegal dismissal and various money claims before the National Labor Relations Commission (NLRC) Regional Arbitration Branch. The Labor Arbiter consolidated the cases and eventually ruled in favor of the petitioners, declaring their dismissals illegal and ordering their reinstatement with full backwages. SRMI appealed to the NLRC, which reversed the Labor Arbiter’s decision, dismissing the complaints for lack of merit. The petitioners filed a motion for reconsideration, which the NLRC denied.
Aggrieved, the petitioners filed a Petition for Certiorari under Rule 65 with the Court of Appeals (CA) to assail the NLRC’s resolutions. However, the CA dismissed the petition outright on procedural grounds. The CA ruled that the verification and certification against forum shopping attached to the petition were defective because they were signed by only one of the petitioners, Henry Yu, without a duly executed Special Power of Attorney (SPA) from his co-petitioners authorizing him to represent them. The petitioners moved for reconsideration, submitting the required SPAs, but the CA denied the motion, holding that the submission could not cure the fatal defect which vested no jurisdiction upon the court from the inception.
ISSUE
Whether the Court of Appeals gravely erred in dismissing the petition for certiorari based solely on the procedural defect in the verification and certification against forum shopping.
RULING
Yes, the Supreme Court ruled that the Court of Appeals committed a reversible error. The Court emphasized that while compliance with the rules on verification and certification against forum shopping is mandatory, the rules of procedure should be tools to facilitate, not frustrate, the administration of justice. Technicalities must yield to substantive rights, especially in labor cases where the constitutional policy of affording protection to labor is paramount.
The defect—the lack of a Special Power of Attorney at the time of filing—was not a fatal flaw that warranted outright dismissal. The Court reiterated the doctrine that a verification signed by only one of the petitioners is acceptable if he acts as a representative, and the subsequent submission of the required authorizations substantially complies with the rules. The petitioners’ subsequent filing of the SPAs during the motion for reconsideration stage cured the initial procedural lapse. The CA’s rigid application of procedural technicalities deprived the petitioners of their day in court and the opportunity to have their substantive claims of illegal dismissal heard on the merits. The Supreme Court thus granted the petition, reversed the CA’s resolutions, and remanded the case to the CA for proper adjudication on the substantive issues.