GR 163013; (April, 2008) (Digest)
G.R. No. 163013 ; April 30, 2008
EUREKA PERSONNEL AND MANAGEMENT SERVICES, INC., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and APOLONIO A. BUENO, respondents.
FACTS
Petitioner Eureka Personnel and Management Services, Inc., a recruitment agency, deployed private respondent Apolonio A. Bueno to work for its foreign principal, Saudi Archirodon, Ltd. Bueno was hired under a contract as a mechanic with a monthly salary of SR$1,763. However, upon deployment on June 14, 1999, he was assigned to work as a carpenter receiving only SR$750 per month. During his employment, Bueno sustained an injury to his right eyebrow. After medical treatment and subsequent examinations showing his eyes were normal, he refused to work and was eventually repatriated on March 21, 2001.
Bueno filed a complaint for illegal dismissal, underpayment of salaries, and damages. The Labor Arbiter ruled in his favor, ordering payment of salary differentials and three months’ salary for the unexpired contract. The NLRC modified this decision on June 30, 2003, deleting the award for the unexpired portion but upholding the salary differential award for the entire 12-month contract period, computed using the mechanic’s stipulated salary rate.
ISSUE
Whether the Court of Appeals erred in dismissing petitioner’s special civil action for certiorari due to failure to comply with the documentary requirements under Section 3, Rule 46 of the Rules of Court.
RULING
The Supreme Court ruled that the Court of Appeals did not err in dismissing the petition. Petitioner filed a special civil action for certiorari under Rule 65 assailing the NLRC decision but failed to attach material documents required by Section 3, Rule 46, in relation to Rule 65. These documents included the complaint for illegal dismissal, the employment contract, the parties’ position papers, and the Labor Arbiter’s decision. While petitioner attached the NLRC decision and resolution, it omitted these foundational pleadings and records.
The legal logic is grounded in procedural compliance. The rules mandate that a petition for certiorari must be accompanied by copies of all relevant pleadings and documents to allow the appellate court a complete basis for review. Petitioner’s core argument—disputing the use of the mechanic’s salary rate for computing differentials—directly necessitated an examination of the employment contract and the parties’ submissions to the Labor Arbiter to assess the merits. The absence of these documents rendered the petition insufficient. The Court rejected petitioner’s plea for liberal application of the rules, as no cogent reason was shown to excuse the non-compliance, especially since petitioner failed to rectify the omissions even after the appellate court pointed them out in its resolution denying reconsideration. Thus, procedural default justified the dismissal.