GR 151833; (August, 2003) (Digest)
G.R. No. 151833 ; August 7, 2003
ANTONIO M. SERRANO, Petitioner, vs. GALANT MARITIME SERVICES, INC., MARLOW NAVIGATION CO., LTD. AND NATIONAL LABOR RELATIONS COMMISSION, Respondents.
FACTS
Petitioner Antonio M. Serrano filed a complaint for illegal dismissal against respondents Galant Maritime Services, Inc. and Marlow Navigation Co., Ltd. The Labor Arbiter ruled in Serrano’s favor, awarding him monetary claims. On appeal, the National Labor Relations Commission (NLRC) modified the decision, reducing the award to three months’ salary and deleting other claims. Serrano’s motion for reconsideration was denied.
Serrano subsequently filed a petition for certiorari with the Court of Appeals, assailing the NLRC’s decision. However, the Court of Appeals issued a Resolution dated January 31, 2001, dismissing the petition outright. The dismissal was based on Serrano’s failure to attach copies of all relevant pleadings and documents as required under Section 1, Rule 65 of the 1997 Rules of Civil Procedure. Serrano filed a motion for reconsideration, attaching the required documents, but the appellate court denied it in a Resolution dated December 18, 2001. Hence, Serrano elevated the case to the Supreme Court via a petition for review on certiorari, arguing that the Court of Appeals erred in dismissing his petition on a mere technicality.
ISSUE
Did the Court of Appeals commit reversible error in dismissing the petition for certiorari based solely on a procedural lapse?
RULING
Yes, the Supreme Court reversed the assailed Resolutions of the Court of Appeals. The Court acknowledged that certiorari is an extraordinary remedy requiring strict adherence to procedural rules. Section 1, Rule 65 mandates that the petition be accompanied by copies of all relevant pleadings and documents, and Section 3, Rule 46 provides that non-compliance is a sufficient ground for dismissal.
However, the Court emphasized that procedural rules are tools to promote, not hinder, the administration of justice. While the Court of Appeals had the discretion to dismiss the petition for the initial procedural lapse, it should have considered that Serrano subsequently attached the required documents in his motion for reconsideration. This constituted substantial compliance. The primordial end is to dispose of cases on their merits. Dismissing the petition on pure technicality, after the documents had been submitted, placed form over substance and risked injustice. The case was remanded to the Court of Appeals for further proceedings on the merits.