G.R. No. 157029. December 15, 2005.
JIMMY KENT RAMBUYON, ET AL., Petitioners, vs. FIESTA BRANDS, INC., Respondent.

FACTS

Petitioners were part of a work pool of extra shellers for respondent Fiesta Brands, Inc., a desiccated coconut manufacturer. They were hired on an as-needed basis during oversupply or as temporary replacements. In August 2000, respondent implemented a new shelling system with a higher daily quota and pay. Petitioners refused to adopt this new system and, as a consequence, were no longer given work assignments. They filed consolidated complaints for illegal dismissal.
The Labor Arbiter dismissed the complaint, finding petitioners were not regular employees but merely extra workers from a pool, and thus were not dismissed but simply not hired due to their refusal of the new system. The NLRC affirmed this decision, upholding management’s prerogative to implement new production measures. Petitioners then filed a special civil action for certiorari with the Court of Appeals.

ISSUE

Whether the Court of Appeals correctly dismissed the petition for certiorari due to a defective verification and certification of non-forum shopping signed by only one of the multiple petitioners.

RULING

Yes, the Court of Appeals correctly dismissed the petition. The Supreme Court affirmed the dismissal based on strict compliance with procedural rules regarding verification and certification against forum shopping.
The legal logic is grounded in the distinct nature and purpose of a certification against forum shopping, as opposed to a mere verification. While verification requires allegations to be true and correct, the certification is a personal undertaking by a party not to engage in forum shopping. For petitions filed by multiple petitioners, the rule mandates that all petitioners must sign the certification. The reason is that forum shopping is a willful act, and the certification is a personal attestation that cannot be made by one party on behalf of others without their specific consent. The Court rejected petitioners’ reliance on Escorpizo v. University of Baguio, clarifying that the exception allowing one signature applies only when petitioners share a common interest and are represented by the same counsel, such as a union and its member. Here, petitioners were individual workers with separate interests in their claims for illegal dismissal. Their proffered excuse of difficulty in locating co-petitioners was deemed insufficient to excuse non-compliance. Procedural rules are not mere technicalities but essential to the orderly administration of justice, and their relaxation is not warranted in this case.