Pfizer, Inc. v. Galan
REITERATIONFacts
The Antecedents: Edwin V. Galan, a former employee of Pfizer, Inc., was dismissed from his position as District Manager for Mindanao in October 1998, after being accused of unauthorized use of a company vehicle and questionable expense claims, as well as the dubious liquidation of a cash advance. Galan had been employed by Pfizer since August 1982 and had received several awards for his performance, eventually earning a promotion. Procedural History: Galan filed a complaint for illegal dismissal against Pfizer, Inc., and its officers Ma. Angelica B. Lleander and Sandra Webb, before the National Labor Relations Commission (NLRC). The Labor Arbiter ruled in favor of Galan, ordering Pfizer to pay him P2,052,013.50 in back wages, separation pay, and other monetary awards. The NLRC affirmed this decision, and petitioners' motion for reconsideration was denied. Subsequently, the NLRC issued a writ of execution. Prior to this, Pfizer and its officers filed a petition for certiorari with the Court of Appeals, which dismissed their petition for being filed beyond the sixty-day reglementary period and for a defective verification. The Petition: Petitioners seek review of the Court of Appeals' dismissal of their certiorari petition. They argue that the dismissal was erroneous because their petition was timely filed under the amended Section 4, Rule 65 of the 1997 Rules of Civil Procedure, which allows sixty days from notice of denial of a motion for reconsideration, and that this amendment should be given retroactive effect. They also contend that the Court of Appeals erred in finding the verification of their petition defective, asserting that the affiant, an employee of Pfizer, had personal knowledge of the case and was acting on behalf of the company. Petitioners invoke the principle of liberal construction of rules to serve substantial justice.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari on the ground that it was filed beyond the sixty-day reglementary period. Whether the Court of Appeals erred in dismissing the petition for certiorari on the ground of a fatally defective verification.
Ruling
The Supreme Court set aside the Resolutions of the Court of Appeals dated November 11, 1999, and May 25, 2000, and remanded the case to the Court of Appeals for further proceedings.
Ratio Decidendi
On the issue of the reglementary period: The Supreme Court held that the amendment to Section 4, Rule 65 of the 1997 Rules of Civil Procedure, introduced by A.M. No. 00-2-03-SC, which allows filing a petition for certiorari within sixty days from notice of the denial of a motion for reconsideration, is procedural and remedial. Such amendments may be given retroactive effect to pending actions. In this case, applying the amended rule, petitioners' petition was filed on time, as it was filed on the sixtieth day from notice of the denial of their motion for reconsideration. The Court emphasized that procedural laws may be given retroactive effect to actions pending and undetermined at the time of their passage, as there are no vested rights in rules of procedure. The amendment in question does not create new rights but merely furthers an existing remedy. Therefore, the Court of Appeals erred in dismissing the petition solely on the basis of the original reglementary period. On the issue of the defective verification: The Supreme Court found that the verification executed by Ms. Cleofe R. Legaspi, an Employment Specialist of Pfizer, Inc., was not fatally defective. The Court clarified that Ms. Legaspi, who coordinated and participated in the investigation of the administrative charges against respondent Galan, had personal knowledge of the facts alleged in the petition. As Pfizer is a corporation, it can only act through its officers, and Ms. Legaspi, having personal knowledge, was acting in behalf of the company. The Court also corrected the Court of Appeals' misinterpretation of Ms. Legaspi's statement, clarifying that her declaration referred to Pfizer, Inc. as "one of the petitioners" and not herself. The purpose of verification, which is to assure that allegations are made in good faith and are true, was served. Therefore, the Court of Appeals erred in dismissing the petition on this ground.
Main Doctrine
Procedural rules, including reglementary periods for filing petitions for certiorari, may be given retroactive effect, especially when amendments are procedural or remedial in character, to serve the interest of substantial justice. A verification by an officer with personal knowledge of the facts, even if not a party to the suit, may be considered valid if it serves the purpose of assuring good faith and truthfulness of allegations.