G.R. No. 143574; July 11, 2002
MANILA HOTEL CORPORATION, petitioner, vs. COURT OF APPEALS and SAMUEL ALCORDO, respondents.

FACTS

Petitioner Manila Hotel Corporation hired private respondent Samuel Alcordo as Food and Beverage Director in March 1998. His services were terminated in November 1998 on the ground of loss of confidence due to his alleged failure to improve the profitability of the restaurants under his supervision. Alcordo filed an illegal dismissal complaint. The Labor Arbiter dismissed the complaint, finding the dismissal justified for a managerial employee, but ordered payment of one month’s salary for lack of procedural due process. The National Labor Relations Commission (NLRC) reversed this decision, ordering Manila Hotel to reinstate Alcordo with full backwages, separation pay, and damages.
Manila Hotel filed a petition for certiorari with the Court of Appeals to assail the NLRC decision. The Court of Appeals dismissed the petition outright on technical grounds. It found the petition was not accompanied by copies of the Labor Arbiter’s decision and the parties’ position papers, which were deemed relevant and pertinent documents. Furthermore, the certificate of non-forum shopping was signed by the company’s counsel without a board resolution authorizing him to act on behalf of the corporation. Petitioner filed a motion for reconsideration, attributing the omissions to inadvertence and subsequently submitting the missing documents, but the appellate court denied the motion.

ISSUE

Whether the Court of Appeals correctly dismissed the petition for certiorari due to petitioner’s failure to comply with the procedural requirements under the Rules of Court.

RULING

Yes, the Court of Appeals correctly dismissed the petition. The Supreme Court affirmed the dismissal, emphasizing strict adherence to procedural rules. Under Rule 46, Section 3, in relation to Rule 65, Section 1 of the 1997 Rules of Civil Procedure, the failure to append copies of the judgment or resolution subject of the petition, together with all relevant and pertinent documents, is a sufficient ground for the dismissal of the petition. In this case, the omitted documents—the Labor Arbiter’s decision and the position papers—were essential for the appellate court to review the factual and legal bases of the conflicting findings between the Labor Arbiter and the NLRC regarding the validity of the dismissal.
The Court rejected petitioner’s plea for liberal construction, holding that the excuse of “oversight” or “inadvertence” is insufficient to warrant relaxation of the rules. Procedural rules are designed to ensure orderliness and efficiency in the administration of justice. While liberal interpretation may be allowed in certain exceptional circumstances to prevent manifest injustice, no such compelling reason was shown here. Petitioner failed to demonstrate that a rigid application would result in a grave miscarriage of justice or that the injustice to the adverse party was disproportionate to the procedural lapse. Therefore, the Court of Appeals did not commit grave abuse of discretion in dismissing the petition on technical grounds.