Camaso v. TSM Shipping (Phils), Inc.
REITERATIONFacts
The Antecedents: Petitioner Woodrow B. Camaso (Camaso) was employed by respondents TSM Shipping (Phils), Inc., Utkilen, and Jones Tulod as Second Mate. While employed, Camaso developed tonsillar cancer, which was confirmed after medical repatriation. Respondents initially paid for his treatment, including chemotherapy and radiation therapy, and sickwage allowances. However, they later refused to shoulder further medical expenses, prompting Camaso to file a complaint for disability benefits, sickwage allowance, reimbursement of medical expenses, and damages before the National Labor Relations Commission (NLRC). Procedural History: The Labor Arbiter (LA) ruled in favor of Camaso, ordering respondents to pay disability benefits and attorney's fees. The NLRC reversed the LA's decision and dismissed Camaso's complaint. Camaso's motion for reconsideration was denied. Consequently, Camaso filed a petition for certiorari before the Court of Appeals (CA). The Petition: The CA dismissed Camaso's petition for certiorari due to non-payment of docket fees. Camaso moved for reconsideration, asserting that a check for the docket fees was attached to his petition, which was allegedly overlooked. The CA denied the motion, citing the presumption of regularity and the fact that the attached check was not a sanctioned mode of payment under its internal rules. Hence, Camaso filed the present petition for review on certiorari.
Issue(s)
Whether the Court of Appeals (CA) correctly dismissed Camaso's petition for certiorari for non-payment of docket fees, considering the circumstances of the case. Whether the rule on payment of docket fees can be relaxed under the attendant circumstances, specifically Camaso's attempt to pay with a Metrobank check.
Ruling
The petition is meritorious. The Resolutions dated August 12, 2015 and March 4, 2016 of the Court of Appeals (CA) in CA-G.R. SP No. 141278-UDK are SET ASIDE. The case is REMANDED to the CA for further proceedings, with the CA directed to order Camaso to pay the required docket fees within thirty (30) days from notice.
Ratio Decidendi
On the dismissal of the petition for non-payment of docket fees: The Court reiterated that Section 3, Rule 46 of the Rules of Court requires the payment of docket fees for original actions filed before the CA, and failure to comply is a ground for dismissal. However, the Court emphasized that the rule on payment of docket fees is not absolute and may be relaxed in exceptional circumstances. Citing Bibiana Farms & Mills, Inc. v. NLRC, the Court noted that while non-payment may render an action dismissible, the court may allow payment within a reasonable time, especially if there is no deliberate refusal or intention to defraud the government. The Court further referenced La Salette College v. Pilotin, stating that dismissal for non-payment is discretionary, not automatic, and should be exercised with sound discretion in accordance with justice and fair play. The Court also recalled Villamor v. CA, which stressed the policy of encouraging hearings on appeals on their merits to avoid miscarriage of justice, holding that resorting to technicalities that frustrate substantial justice should be avoided. Therefore, the strict application of the rule on docket fees can be qualified by the attending circumstances. On the application of the rule to the present case: The Court found that Camaso's petition for certiorari was accompanied by a Metrobank check intended as payment for docket fees, demonstrating earnest efforts to comply. Although the check was not an authorized mode of payment under the 2009 Internal Rules of the Court of Appeals (IRCA), its attachment indicated good faith and an intention not to defraud the government. The Court noted that the CA's assertion of non-receipt of the check was contradicted by the fact that it was found stapled to the petition when examined at the Office of the Division Clerk of Court. Given these circumstances, the Court deemed it appropriate to relax the technical rules of procedure in the interest of substantial justice. The case was remanded to the CA with a directive to order Camaso to pay the required docket fees within a reasonable period of thirty (30) days from notice.
Main Doctrine
The strict application of the rule on payment of docket fees may be relaxed in the interest of substantial justice, provided there is no intention to defraud the government and earnest efforts to pay were made.