GR 159969; (November, 2005) (Digest)
G.R. No. 159969 & 160116 November 15, 2005
BECTON DICKINSON PHILS., INC. and WILFREDO JOAQUIN, Petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, HON. LABOR ARBITER EDGARDO M. MADRIAGA and REINERIO Z. ESMAQUEL, Respondents.
FACTS
Private respondent Reinerio Z. Esmaquel was employed by petitioner Becton Dickinson Philippines, Inc. (Becton) in 1989, eventually rising to the position of Business Director. In 2001, he was terminated from employment on the grounds of redundancy and alleged performance issues. Esmaquel filed a complaint for illegal dismissal against Becton and its then Country Manager, Wilfredo Joaquin. The Labor Arbiter ruled the dismissal illegal, holding Becton solely liable for monetary awards but finding that Joaquin acted jointly in the termination.
Petitioners Becton and Joaquin jointly appealed to the NLRC. The NLRC dismissed their appeal for failure to comply with a procedural rule requiring a certification of non-forum shopping, as mandated by NLRC Resolution No. 01-02. Their subsequent petition for certiorari before the Court of Appeals was dismissed, affirming the NLRC’s dismissal both on procedural grounds and for lack of merit. Petitioners filed separate petitions for review with the Supreme Court.
ISSUE
Whether the NLRC committed grave abuse of discretion in dismissing the petitioners’ appeal for failure to attach a certification of non-forum shopping.
RULING
The Supreme Court denied the petitions and affirmed the Court of Appeals. The NLRC did not commit grave abuse of discretion in dismissing the appeal for procedural non-compliance. NLRC Resolution No. 01-02, which amended its rules to require a certification of non-forum shopping in appeals, is a valid exercise of the NLRC’s rule-making power. The requirement is not merely technical but essential to prevent forum shopping, ensure orderly administration of justice, and promote the expeditious determination of labor cases. The Court emphasized that rules of procedure, especially those promulgated by quasi-judicial bodies like the NLRC, are binding and must be strictly followed. The petitioners’ failure to attach the required certification was a fatal procedural flaw that warranted the dismissal of their appeal. The Court further found that, even if the procedural defect were overlooked, the dismissal was justified on substantive grounds as no grave abuse of discretion attended the NLRC’s affirmation of the Labor Arbiter’s finding of illegal dismissal.