Rambuyon v. Fiesta Brands, Inc.
REITERATIONFacts
The Antecedents: Respondent Fiesta Brands, Inc., engaged in manufacturing desiccated coconut for export, employed shellers. The company implemented a new shelling system in August 2000, offering a higher daily rate but with an increased quota. Petitioners, who were extra shellers, refused to adopt this new system. Consequently, they were not given preference in hiring and found themselves jobless. Procedural History: Petitioners filed consolidated cases for illegal dismissal against Fiesta Brands, Inc. The Labor Arbiter dismissed their complaint, finding that the extra shellers were not regular employees and had refused to work under the new system. The National Labor Relations Commission (NLRC) affirmed this decision, upholding the company's management prerogative. After the NLRC denied their motion for reconsideration, petitioners filed a special civil action for certiorari with the Court of Appeals. The Petition: The Court of Appeals dismissed the petitioners' special civil action for certiorari due to the insufficiency of the verification and certification of non-forum shopping, which were signed by only one of the ten petitioners. Petitioners seek review of this dismissal, arguing that the rules do not require all parties to sign these documents and that their difficulty in locating all co-petitioners was a valid excuse. They also reassert their claim of illegal dismissal, asserting they were regular employees terminated without just cause. The Supreme Court, however, found their arguments unmeritorious, noting that the cited jurisprudence did not support their interpretation and that SC Circular No. 28-91, as amended, mandates all petitioners to sign the certification. The Court also found the excuse for not obtaining all signatures untenable, as all petitioners had previously signed other pleadings, and affirmed the dismissal of the petition.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari on the ground of violation of Sections 4 and 5 of Rule 7 of the Rules of Civil Procedure. Whether the Court of Appeals abused its discretion in disregarding the petitioners' explanation for the inability to jointly sign the verification and certification of non-forum shopping. Whether the Court of Appeals abused its discretion in not preventing a miscarriage of justice and not applying the principle of social justice and protection to labor. Whether petitioners were illegally dismissed.
Ruling
The petition is DENIED. The assailed resolutions of the Court of Appeals are AFFIRMED.
Ratio Decidendi
On the issue of the Court of Appeals' dismissal for insufficient verification and certification of non-forum shopping: The Court held that the petitioners' reliance on Escorpizo v. University of Baguio was misplaced, as that case dealt with a certification signed by counsel, not by a principal party. The established rule, as per SC Circular No. 28-91 and Administrative Circular No. 04-94, mandates that the certification of non-forum shopping must be signed by all petitioners. While Loquias v. Office of the Ombudsman qualified this by allowing a single signatory if duly authorized, there was no showing of such authorization here. The Court found the excuse of difficulty in locating co-petitioners untenable, as records indicated they had previously signed documents together, negating the claim of inability to coordinate. Therefore, the Court of Appeals did not err in dismissing the petition for being insufficient in form. On the issue of disregarding the explanation for the inability to sign: The Court found the explanation that it was difficult to locate co-petitioners to be untenable. This was because the records showed that Jimmy Kent Rambuyon, the sole signatory, had previously signed the verification of the Position Paper filed with the Labor Arbiter along with his nine co-petitioners. This demonstrated that coordination was possible and that there was no genuine difficulty in having all petitioners sign the required documents. Thus, the Court was not prepared to indulge a plea for liberal construction of the rules under these circumstances. On the issue of preventing miscarriage of justice and applying social justice: While the Court adheres to the principle of social justice and protection to labor, it found the instant petition bereft of merit. The procedural defect in the certification of non-forum shopping was a clear violation of the Rules of Court, and liberal construction cannot be invoked to justify utter disregard of the rules. The attestation in the certification requires personal knowledge, which cannot be presumed for absent co-petitioners. On the issue of illegal dismissal: The Court reiterated that a petition for review on certiorari is limited to questions of law, and the issue of whether petitioners were regular employees and were dismissed without just cause and due process is a factual issue. These factual matters had been exhaustively passed upon and resolved against the petitioners by both the Labor Arbiter and the NLRC. The Court affirmed that factual findings of quasi-judicial bodies, when supported by substantial evidence, are generally accorded great respect and finality. In this case, there was no cogent reason to disturb the findings that petitioners were not illegally dismissed and were not regular employees.
Main Doctrine
A petition for certiorari dismissed due to insufficient verification and certification of non-forum shopping, where the sole signatory was not shown to be authorized by co-petitioners, will not be given liberal construction, especially when the signatory had previously signed similar documents with co-petitioners, indicating no actual difficulty in their coordination.