G.R. No. 204325 . April 18, 2016.
LYNMAN BACOLOR, JEFFREY R. GALURA, HELEN B. TORRES, FRITZIE C. VELLEGAS, RAYMOND CANLAS AND ZHEILA C. TORRES, PETITIONERS, VS. VL MAKABALI MEMORIAL HOSPITAL, INC., ALEJANDRO S. MAKABALI, MELCHOR CATAMBING AND DAX M. TIDULA, RESPONDENTS.

FACTS

Petitioners, resident physicians at VL Makabali Memorial Hospital, Inc., filed an amended complaint for illegal dismissal and money claims against the Hospital, its owner, and its ER Manager. They alleged that after their initial fixed-term contracts expired, they were continuously employed. In May 2006, they were instructed to resign and re-apply under new one-year contracts, and upon refusal, were demoted to assistant physicians in the Operating Room. Notices to explain were issued against some petitioners, and Drs. Bacolor and Galura were later terminated. Dr. Tidula, also a resident physician, alleged he was dismissed for violating timekeeping procedures after he implemented a reliever system and punched the time card of an absent doctor. The Labor Arbiter ruled in favor of petitioners and Dr. Tidula, finding illegal dismissal. The NLRC reversed the decision, dismissing the complaints. Petitioners filed a Petition for Certiorari with the Court of Appeals. The Petition was accompanied by three separate Verifications/Certificates of Non-Forum Shopping signed by Drs. Galura, Bacolor, and Helen. Atty. Carlos Raphael N. Francisco executed a Verification/Certificate of Non-Forum Shopping with Undertaking on behalf of Drs. Villegas, Canlas, and Zheila. The CA dismissed the Petition due to a defective Verification/Certificate of Non-Forum Shopping, as the one for Drs. Villegas, Canlas, and Zheila was signed by their counsel and not by the petitioners themselves, and for violation of Section 3, Rule 46 for not indicating in the title that Dax Tidula was a party respondent and not indicating his address. The CA denied their Motion for Reconsideration.

ISSUE

Whether the Court of Appeals erred in dismissing the Petition for Certiorari based on technical grounds, specifically: (1) the defective Verification/Certificate of Non-Forum Shopping executed by counsel for some petitioners, and (2) the non-compliance with Section 3, Rule 46 regarding the title and address of a party respondent.

RULING

The Supreme Court granted the Petition. The ruling emphasized that rules of procedure should be used to achieve speedy and efficient justice and not to derail it. Liberal construction of the rules on verification and non-forum shopping is warranted when strict application would result in a patent denial of substantial justice. The Court found that the petitioners substantially complied with the rules. Regarding the Verification/Certificate of Non-Forum Shopping, the undertaking signed by counsel for three petitioners substantially complied with the rules, as it was a reasonable cause for not executing the certification themselves. The Court cited precedents where similar circumstances were considered substantial compliance. Regarding the failure to indicate Dax Tidula as a respondent in the title and his address, the Court ruled this was a formal, not jurisdictional, defect that did not mislead or prejudice the parties, as Tidula was named in the body of the Petition and was served a copy through counsel. The case was remanded to the Court of Appeals for resolution on the merits.