G.R. No. 230696 . August 30, 2017.
WILLIAM R. WENCESLAO, ET AL., PETITIONERS, VS. MAKATI DEVELOPMENT CORPORATION, DANTE ABANDO AND COURT OF APPEALS, RESPONDENTS.

FACTS

The petitioners, former construction workers of respondent Makati Development Corporation (MDC), filed a complaint for illegal dismissal and monetary claims. They alleged they were regular employees illegally dismissed for refusing to transfer to a different contractor. The Labor Arbiter dismissed the complaint, ruling the petitioners were project employees, a status not altered by their rehiring for successive projects, and only awarded prorated 13th-month pay. The National Labor Relations Commission (NLRC) affirmed this decision in toto. The petitioners subsequently filed a Petition for Certiorari before the Court of Appeals (CA) assailing the NLRC’s resolutions.
The CA dismissed the petition primarily on procedural grounds due to fatal deficiencies. It found the petition non-compliant with Section 3, Rule 46 of the Rules of Court, as it failed to attach certified true copies of the assailed NLRC Decision and Resolution. Instead, mere photocopies of purported certified copies were submitted. The CA also noted the petition lacked other essential documents, including the Labor Arbiter’s decision, the petitioners’ appeal memorandum, and motion for reconsideration, which are necessary for a complete understanding of the case. The petitioners’ motion for reconsideration was denied.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in dismissing the Petition for Certiorari on purely procedural grounds.

RULING

No, the CA did not commit grave abuse of discretion. The Supreme Court affirmed the CA’s dismissal, emphasizing that rules of procedure are indispensable for the orderly administration of justice. The requirement to submit certified true copies of the questioned judgments and material portions of the record is mandatory. The petitioners’ failure to attach these vital documents was a fatal flaw that warranted the petition’s dismissal. The Court clarified that a certiorari petition is an original action; it is not an appeal. Consequently, the CA must have all relevant documents before it to determine whether the NLRC committed grave abuse of discretion. Without the certified true copies of the assailed resolutions and the complete records, the CA could not properly exercise its power of judicial review.
The Court rejected the petitioners’ argument that the dismissal was based on a mere technicality, citing established jurisprudence that procedural rules are not to be belittled or dismissed as trivial. While litigation should be decided on merits, this principle presupposes that parties faithfully comply with procedural requirements. The petitioners’ non-compliance was substantial, not merely formal. Furthermore, the Court examined the petition’s merits and found it failed to sufficiently demonstrate that the NLRC acted with grave abuse of discretion. The NLRC’s findings, which affirmed the Labor Arbiter’s conclusion that the petitioners were project employees, were supported by evidence and accorded with applicable law. Thus, the CA’s dismissal was legally sound and upheld.