GR 164582; (March, 2007) (Digest)
G.R. No. 164582 March 28, 2007
PILAR ESPINA, ET AL., Petitioners, vs. HON. COURT OF APPEALS, MONDE M.Y. SAN BISCUIT CORP., ET AL., Respondents.
FACTS
Petitioners were employees of M.Y. San Biscuits, Inc. The company announced the sale of its business and assets to Monde M.Y. San Corporation, resulting in the termination of all employees effective January 31, 2001. A Memorandum of Agreement (MOA) was executed between the company and the union, providing for separation pay, cash equivalents for leave credits, and a clause stating that employees would be given hiring preference by the new owner, Monde, subject to its qualifications. Petitioners received their separation benefits and signed quitclaims. Subsequently, they filed complaints for illegal dismissal, alleging they were not rehired by Monde, constituting a violation of the hiring preference clause in the MOA.
The labor arbiter dismissed the complaints, a decision affirmed by the National Labor Relations Commission (NLRC). Petitioners elevated the case to the Court of Appeals via a Petition for Certiorari. The Court of Appeals dismissed the petition outright due to a procedural defect: the attached certification of non-forum shopping was not signed by all petitioners, in violation of the rules.
ISSUE
Whether the Court of Appeals correctly dismissed the petition for certiorari due to the petitioners’ failure to comply with the requirement that all petitioners must sign the certification of non-forum shopping.
RULING
Yes, the Court of Appeals was correct. The Supreme Court affirmed the dismissal, emphasizing the mandatory and jurisdictional nature of the rule on certifications of non-forum shopping under Section 3, Rule 46 of the Rules of Court. The rule explicitly requires that a petition filed with the Court of Appeals must be accompanied by a certification against forum shopping signed by all petitioners. Non-compliance warrants the petition’s outright dismissal.
The legal logic is rooted in the purpose of the rule, which is to prevent forum shopping and ensure that a party does not seek relief from multiple courts simultaneously, which wastes judicial resources and can lead to conflicting decisions. The requirement is not a mere technicality but a condition sine qua non for the exercise of the court’s jurisdiction. The petitioners’ failure to have all co-parties sign the certification was a fatal defect. Their subsequent motion to drop the names of those who did not sign was correctly denied, as the rule requires the signature of all petitioners at the time of filing. The Court held that procedural rules are tools to facilitate the orderly administration of justice, and strict compliance is required, especially for a special civil action like certiorari.