GR 147478; (July, 2006) (Digest)
G.R. No. 147478 ; July 17, 2006
METRO DRUG DISTRIBUTION, INC., ET AL., petitioners, vs. NOEL M. NARCISO, respondent.
FACTS
Respondent Noel M. Narciso filed an illegal dismissal complaint against petitioners. The Labor Arbiter dismissed the complaint, a decision affirmed by the NLRC, which, however, modified it by awarding separation pay to Narciso. Petitioners filed a motion for reconsideration challenging this award, which the NLRC denied. Subsequently, petitioners elevated the case via a petition for certiorari under Rule 65 to the Court of Appeals.
The Court of Appeals dismissed the petition outright on procedural grounds. It found two fatal defects: first, the petition’s caption failed to specify all the petitioners as required by Section 1, Rule 7 of the Rules of Court; and second, the attached certification against forum shopping was executed by the corporate Vice-President for Finance and Human Resources without any proof of authority from the Board of Directors to represent the corporation and the individual petitioners. Petitioners filed a motion for reconsideration but committed the same procedural errors, failing to correct the defective caption and to submit the required proof of authority.
ISSUE
Whether the Court of Appeals gravely abused its discretion in dismissing the petition for certiorari based on procedural infirmities.
RULING
The Supreme Court denied the petition, upholding the appellate court’s dismissal. The Court acknowledged the policy of liberal construction of procedural rules to secure substantial justice. However, this liberality is not an excuse for blatant disregard of the rules. Procedural rules are necessary for the orderly administration of justice and should not be ignored at will.
Petitioners failed to meet the basic procedural requirements. The rule mandating the inclusion of all party names in the caption of an original petition is clear. Despite the dismissal of their petition for this reason, petitioners carelessly repeated the same error in their motion for reconsideration. Furthermore, the certification against forum shopping was defective. The Court, citing Zulueta v. Asia Brewery, Inc., ruled that the certification requirement applies to corporations, and the signatory must demonstrate authority to represent the juridical entity. Petitioners offered no such proof initially or upon motion for reconsideration. Their justification—that the rules allegedly applied only to original complaints—was untenable. Compliance at the reconsideration stage could have cured the defects, but petitioners chose not to rectify them. Thus, the Court of Appeals correctly denied the petition for failure to adhere to mandatory procedural rules.