GR 155875; (April, 2003) (Digest)
G.R. No. 155875 ; April 3, 2003
Agapito Cruz Fiel, Avelino Quimson Reyes, and Roy Conales Bonbon, petitioners, vs. Kris Security Systems, Inc., National Labor Relations Commission, and the Court of Appeals, respondents.
FACTS
Petitioners were security guards employed by Kris Security Systems, Inc., assigned to a client in Imus, Cavite. Their services were terminated in October 1998. They filed a complaint for illegal dismissal before the NLRC. The Labor Arbiter ruled in their favor, finding constructive dismissal and ordering reinstatement with full backwages. However, the NLRC, on appeal, reversed this decision and dismissed the complaints.
Petitioners subsequently filed a petition for certiorari under Rule 65 with the Court of Appeals. The appellate court dismissed the petition outright on a procedural ground. It found that the petition violated Section 5, Rule 7 of the 1997 Rules of Civil Procedure, as only three out of the four named petitioners (Agapito Fiel, Avelino Reyes, and Roy Bonbon) signed the mandatory verification and certification against forum shopping. The fourth petitioner, Diomedes Uray, did not sign. The Court of Appeals denied their motion for reconsideration.
ISSUE
Whether the Court of Appeals acted correctly in dismissing the entire petition for certiorari due to the failure of one co-petitioner to sign the verification and certification against forum shopping.
RULING
The Supreme Court ruled that the Court of Appeals erred. The petition is granted. The assailed resolutions are set aside, and the case is remanded to the Court of Appeals for adjudication on the merits.
The legal logic is anchored on the principle that rules of procedure are tools to promote, not frustrate, substantial justice. While strict compliance with the rule on verification and certification is generally required, a rigid application that sacrifices substantive rights is not justified. The three petitioners who duly signed the certification should not be prejudiced by the omission of their co-petitioner, who appeared to have lost interest. The Court distinguished the situation from prior strict rulings, emphasizing that the objective is to decide cases on their merits. Dismissing the entire petition on this technicality would unjustly deprive the compliant petitioners of their right to be heard on the alleged grave abuse of discretion by the NLRC. The interest of justice is better served by allowing the petition to proceed for the three signatory petitioners.