Ateneo de Naga University v. Manalo
REITERATIONFacts
The Antecedents: Respondent Jovita S. Manalo filed a complaint for constructive dismissal, seeking moral and exemplary damages and attorney's fees, against petitioners Ateneo de Naga University (ADNU), its Dean of the College of Commerce Edwin P. Bernal, and its President Fr. Joel Tabora, S.J. The dispute arose when respondent was transferred from the Accountancy Department to the Department of Social Sciences after being accused of mismanagement of the Ateneo de Naga Multi-Purpose Cooperative. The Labor Arbiter found respondent to have been constructively dismissed and ordered ADNU to reinstate her, pay her salary increases and benefits, and award attorney's fees, but denied moral and exemplary damages. Procedural History: The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision in its resolution dated March 26, 2002, and denied the motion for reconsideration filed by petitioners and Fr. Tabora on August 30, 2002. Subsequently, petitioners and Fr. Tabora filed a petition for certiorari with the Court of Appeals (CA), docketed as CA-G.R. SP No. 74899, alleging grave abuse of discretion by the NLRC. The CA, in a resolution dated January 23, 2003, dismissed the petition, finding the verification and certification against forum shopping fatally defective because they were signed only by Fr. Tabora, not all petitioners. Their motion for reconsideration was denied by the CA on October 3, 2003, with respect to petitioners ADNU and Bernal, but granted for Fr. Tabora. The Petition: Petitioners ADNU and Bernal seek review of the CA's dismissal of their petition for certiorari via a petition for review on certiorari under Rule 45 of the Rules of Court. They argue that the CA committed gross and prejudicial error by dismissing their petition on technical grounds, asserting substantial compliance with the rules on verification and certification against forum shopping. They contend that Fr. Tabora was authorized to sign on their behalf, as evidenced by a Special Power of Attorney and Secretary's Certificates, and that the dismissal denied them substantial justice. The core issue is whether the CA correctly dismissed the petition for certiorari due to the verification and certification being signed by only one of the three petitioners, despite subsequent submission of proof of authority.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari filed by petitioners Ateneo de Naga University and Edwin P. Bernal on the ground of defective verification and certification against forum shopping, and whether the belated submission of a Special Power of Attorney and Secretary's Certificates constitutes substantial compliance with the rules on verification and certification against forum shopping.
Ruling
The petition is GRANTED. The assailed Resolutions of the Court of Appeals are SET ASIDE, and the case is ordered REINSTATED as far as petitioners Ateneo de Naga University and Edwin P. Bernal are concerned for further proceedings.
Ratio Decidendi
On the issue of defective verification and certification against forum shopping and substantial compliance: The Supreme Court found merit in the petition, holding that the Court of Appeals erred in dismissing the petition for certiorari filed by petitioners ADNU and Bernal. The Court emphasized that rules of procedure are tools to achieve substantial justice and should not be used to impede it. The Court noted that while the verification and certification were signed only by Fr. Tabora, he was duly authorized to sign on behalf of ADNU and Bernal, as evidenced by a Special Power of Attorney and Secretary's Certificates. Although these documents were submitted belatedly, they confirmed Fr. Tabora's authority to act for the petitioners in filing the petition before the CA. The Court reiterated that a strict and literal application of the rules on non-forum shopping and verification may be liberally construed when such application would result in a patent denial of substantial justice. The Court held that the belated submission of the Special Power of Attorney and Secretary's Certificates did not defeat the petition. These documents, being notarized public documents, are presumed to be valid in the absence of clear and convincing evidence to the contrary. The Court found that these documents sufficiently established Fr. Tabora's authority to sign the verification and certification against forum shopping on behalf of petitioners ADNU and Bernal. The Court reasoned that the delay in presenting proof of authority should not prejudice the petitioners, especially since the proof was submitted before the CA resolved to uphold the dismissal. The Court concluded that dismissing the petition on technicality would exalt form over substance and result in a denial of substantial justice, particularly given the substantial interests of ADNU and Bernal in the case.
Main Doctrine
The Court reiterated that rules of procedure, including those on verification and certification against forum shopping, are established to secure substantial justice and should not be used to derail it. Substantial compliance may be considered, especially when a strict application would result in a patent denial of justice. Belatedly submitted proof of authority for a signatory, if notarized and not overcome by clear and convincing evidence, can validate the petition.