GR 154448; (August, 2003) (Digest)
G.R. No. 154448 ; August 15, 2003
DR. PEDRITO F. REYES, Petitioner, vs. COURT OF APPEALS, PHIL. MALAY POULTRY BREEDERS, INC. and LEONG HUP POULTRY FARM SDN, BHD., Mr. Francis T.N. Lau, President and Chairman of the Board and Mr. Chor Tee Lim, Director, Respondents.
FACTS
Petitioner Dr. Pedrito F. Reyes was employed by respondent Leong Hup Poultry Farm SDN, BHD and later became General Manager of its Philippine subsidiary, Philmalay. In 1997, amid company losses, petitioner verbally notified the company of his intent to resign by year-end. He later formalized this in a January 1998 letter, requesting various benefits including separation pay, leave conversions, salary adjustments, a car, life insurance premiums, office rental for his home, and continued legal defense in a related criminal case. Respondent Philmalay instead retrenched him effective January 20, 1998, offering only four months’ separation pay, which petitioner rejected.
Petitioner filed a complaint with the NLRC. The Labor Arbiter ruled in his favor, awarding monetary claims for unpaid salary, underpayment, leave conversions, separation pay, and the specific benefits he requested, plus moral and exemplary damages. Respondents appealed to the NLRC, which reversed the Labor Arbiter’s decision. Petitioner then filed a petition for certiorari with the Court of Appeals.
ISSUE
Whether the Court of Appeals correctly dismissed the petition for certiorari for failure to attach the duplicate original or certified true copy of the Labor Arbiter’s decision and other relevant pleadings.
RULING
Yes, the Court of Appeals acted correctly. The Supreme Court affirmed the dismissal, emphasizing strict compliance with procedural rules. Under Section 1, Rule 65 of the Rules of Court, a petition for certiorari must be accompanied by a certified true copy of the judgment, order, or resolution subject thereof, and copies of all pleadings and documents relevant to the petition. The Court ruled that the submission of these documents is indispensable. Their absence deprives the court of the means to verify the factual allegations of the petition and to properly determine the existence of grave abuse of discretion. The requirement is not a mere technicality but a crucial component of due process and orderly judicial administration.
The Court held that the petitioner’s failure to attach the Labor Arbiter’s decision and material pleadings was fatal to his cause. He offered no compelling reason to justify this procedural lapse. While litigation should be decided on merits, this principle presupposes that parties adhere to the rules of procedure. Relaxation of the rules is not warranted when, as in this case, the neglect is unexcused and undermines the very foundation for judicial review. Consequently, the Court of Appeals did not commit reversible error in dismissing the petition for non-compliance with mandatory procedural requirements.