GR 153199; (December, 2002) (Digest)
G.R. No. 153199 December 17, 2002
GENERAL MILLING CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and DATIVO M. CACHO, respondents.
FACTS
The case originated from a complaint for illegal dismissal filed by private respondent Dativo M. Cacho against petitioner General Milling Corporation. The Labor Arbiter found Cacho illegally dismissed, a decision affirmed by the National Labor Relations Commission (NLRC) on appeal. Petitioner then filed a petition with the Court of Appeals. The appellate court dismissed the petition because it was not accompanied by a board resolution or a secretary’s certificate proving that the person who signed the attached Certification of Non-Forum Shopping was duly authorized by the corporation to do so. In its motion for reconsideration, petitioner explained that the signatory was duly authorized and attached the corresponding board resolution. The Court of Appeals denied the motion for reconsideration. Petitioner thus elevated the case to the Supreme Court via a petition for review on certiorari. Private respondent opposed, citing the case of Melo vs. Court of Appeals to argue that compliance with the certification requirement should not be subject to a party’s “afterthought.”
ISSUE
Whether the Court of Appeals erred in dismissing the petition due to the initial failure to attach the board resolution authorizing the signatory of the Certification of Non-Forum Shopping, which was subsequently submitted with the motion for reconsideration.
RULING
The Supreme Court GRANTED the petition. The Court distinguished this case from Melo vs. Court of Appeals, where there was a complete failure to attach a Certification of Non-Forum Shopping. Here, petitioner complied with the requirement to submit the certification itself; the only defect was the initial absence of the proof of the signatory’s authority. The board resolution was subsequently attached to the motion for reconsideration, establishing that the signatory was in fact duly authorized. The Court held there was substantial compliance with the procedural rules and no attempt to ignore them. The Court emphasized that rules of procedure are intended to promote, not frustrate, the ends of justice, and their rigid enforcement may be relaxed to attain the prime objective of dispensing substantial justice. The Supreme Court ordered the reinstatement of CA-G.R. SP No. 66537 and its remand to the Court of Appeals for further proceedings.