GR 158311; (November, 2004) (Digest)
G.R. No. 158311 November 17, 2004
HUNTINGTON STEEL PRODUCTS, INC. & SERAFIN NG, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, JAIME ORBASE, ET AL., respondents.
FACTS
Private respondents, employees, filed an illegal dismissal complaint against petitioners Huntington Steel Products, Inc. and its President. Petitioners moved to dismiss the complaint because the initiatory pleading lacked the certification of non-forum shopping required by Supreme Court Administrative Circular No. 04-94. The Labor Arbiter granted the motion and dismissed the case. On appeal, the NLRC reversed the Labor Arbiter and remanded the case for further proceedings, holding that the defect should be corrected below. The NLRC’s order was affirmed by the Court of Appeals.
ISSUE
Whether the complaint should be dismissed for failure to attach a certification of non-forum shopping at the time of its filing.
RULING
No. The Supreme Court denied the petition and affirmed the appellate court’s decision. While the certification of non-forum shopping is mandatory, its strict application in labor cases must yield to the constitutional mandate for the protection of labor and the state’s policy to afford full protection to workers. The Court emphasized that technical rules of procedure are not binding in labor proceedings and should not be strictly applied if the result would be detrimental to the workingman, as held in The New Valley Times Press v. NLRC.
The legal logic is anchored on the principle of substantial justice. The private respondents substantially complied with the requirement by subsequently including the certification in their position paper. More importantly, the complaint form provided by the NLRC’s docket section at the time lacked a provision for such a certification. To dismiss the case for this formal defect would be a denial of substantive justice, as it would punish the employees for a deficiency in the form supplied by the Commission itself. The NLRC correctly exercised its authority under Article 218(c) of the Labor Code to waive any formal defect or irregularity in the interest of resolving the dispute on its merits. The paramount objective is to decide cases on the substantive rights of the parties, not on technicalities.