GR 142405; (September, 2004) (Digest)
G.R. No. 142405; September 30, 2004
ABAPO, FAUSTINO, et al., petitioners, vs. THE COURT OF APPEALS and SAN MIGUEL CORPORATION, respondents.
FACTS
The petitioners are 120 former employees of San Miguel Corporation (SMC) at its Mandaue Brewery Plant. In 1991, SMC implemented a modernization program, introducing high-speed machines that rendered several functions redundant. Consequently, SMC terminated the affected employees in 1992, offering them a separation package including 175% of monthly salary per year of service, which they accepted. They executed quitclaims before the DOLE.
Two years later, the employees filed complaints for illegal dismissal, alleging the modernization was a pretext for a mass layoff. The Labor Arbiter dismissed the complaints, a decision affirmed by the National Labor Relations Commission (NLRC). The petitioners then filed a special civil action for certiorari with the Court of Appeals.
ISSUE
Whether the Court of Appeals gravely abused its discretion in dismissing the petitioners’ special civil action for certiorari.
RULING
No, the Court of Appeals did not commit grave abuse of discretion. The dismissal was procedurally sound. The petitioners failed to attach a certified true copy of the assailed NLRC Resolution to their petition, a clear violation of Section 3, Rule 46 of the 1997 Rules of Civil Procedure, which explicitly states such failure is a sufficient ground for dismissal. The excuse of voluminous documents and organizational oversight by counsel is unavailing, as adherence to procedural rules is mandatory.
Furthermore, the petitioners admitted they filed the petition seven days beyond the reglementary period. Even if the Court were to overlook these procedural lapses, the petition would still fail on substantive grounds. The Supreme Court cited a prior case involving the same SMC modernization program, ruling the installation of labor-saving devices was a valid ground for termination under the Labor Code. The quitclaims, signed after receiving considerable benefits, constituted binding settlements. Thus, no grave abuse of discretion attended the appellate court’s dismissal based on strict compliance with procedural rules.