Jacinto v. Gumaru
REITERATIONFacts
The Antecedents: Respondent Edgardo Gumaru, Jr. filed a labor case against petitioner Joselito Ma. P. Jacinto and F. Jacinto Group, Inc. On December 6, 2004, a decision was rendered finding the respondents jointly and severally liable to pay the complainant separation pay, other monetary claims including unpaid wages and allowances, moral damages, exemplary damages, and attorney's fees. The decision also stipulated legal interest on the withheld amounts. Procedural History: Petitioner and F. Jacinto Group, Inc. appealed the labor arbiter's decision to the National Labor Relations Commission (NLRC), but the appeal was dismissed for failure to post the required bond, rendering the December 6, 2004 decision final and executory. A writ of execution was issued, leading to the levy of petitioner's real property. Petitioner filed a motion to lift and annul the levy, which was initially denied by the Labor Arbiter. However, the NLRC set aside the Labor Arbiter's order and granted the motion to lift and annul the levy, remanding the case for proper execution proceedings. Petitioner then filed a petition for certiorari with the Court of Appeals (CA) assailing the NLRC's resolutions. The Petition: Petitioner filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, seeking to set aside the CA's resolutions that dismissed his petition for certiorari. The CA dismissed the petition due to a defective verification and certification against forum shopping, as it was signed by petitioner's counsel instead of the petitioner himself, despite petitioner being abroad. Petitioner argued that his counsel was authorized to sign, that he was unable to return due to his physical condition, and that the verification requirement should be relaxed or considered substantially complied with. He also argued that the labor arbiter's decision had not attained finality. However, the Supreme Court found the petition moot and academic, as respondent had manifested that the judgment award had been fully satisfied, rendering the case terminated and beyond review.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari due to a defective verification and certification against forum shopping, and whether the submission of an affidavit while abroad constitutes substantial compliance. Whether the Court of Appeals should have given due course to the petition for certiorari, considering the alleged procedural oversight and the merits of the case, but also considering the subsequent satisfaction of the judgment award rendering the case moot.
Ruling
The Supreme Court denied the Petition for Review on Certiorari for being moot and academic. The Court found that the judgment award in the labor case had been satisfied in full, rendering the case terminated and beyond judicial review.
Ratio Decidendi
On the issue of the defective verification and certification against forum shopping: The Court acknowledged that a party unable to sign the verification and certification against forum shopping may execute a special power of attorney authorizing their counsel to sign on their behalf, as supported by jurisprudence. The Court noted that the petitioner's submission of an affidavit while abroad, attesting to the truthfulness of the petition's allegations and certifying non-forum shopping, could be considered substantial compliance under reasonable or justifiable circumstances. However, this procedural aspect was rendered moot by subsequent events. On the issue of the mootness of the case: The Court held that the Petition had become moot and academic because, as manifested by the respondent and not disputed by the petitioner, the judgment award in the labor case had been satisfied in full. The Court reiterated the principle that once a judgment has been fully satisfied, the case is deemed terminated and passes beyond review. Satisfaction of the judgment is the final act and end of the proceedings, producing a permanent and irrevocable discharge. Therefore, a judgment debtor who acquiesces to and voluntarily complies with the judgment is estopped from appealing it. The Court emphasized that there are no more proceedings to speak of when a judgment has been satisfied.
Main Doctrine
A case becomes moot and academic when the judgment sought to be reviewed has been fully satisfied, rendering the proceedings terminated and the matter beyond judicial review. Satisfaction of the judgment produces a permanent and irrevocable discharge, estopping the judgment debtor from appealing.