CASE DIGEST: Dr. Reyes v. Court of Appeals

 

DR. PEDRITO F. REYES, petitioner, vs. COURT OF APPEALS, PHIL. MALAY POULTRY BREEDERS, INC. and LEONG HUP POULTRY FARM SDN, BHD., Mr. Francis T.N. Lau, President and Chairman of the Board and Mr. Chor Tee Lim, Director, respondents

G.R. No. 154448                |              August 15, 2003

FACTS:

On August 24, 1989, respondent Leong Hup Poultry Farms SDN. BHD of Malaysia, thru its Managing Director Francis T. Lau, appointed petitioner Pedrito F. Reyes as Technical/Sales Manager. Sometime in 1992, the company formed Philippine Malay Poultry Breeders, Inc., in the Philippines. Petitioner was appointed General Manager thereof.

In 1996-1997, respondents suffered losses which caused them to reduce production and retrench employees in Philmalay. On June 30, 1997, petitioner gave verbal notice to respondent Francis T. Lau that he will serve as General Manager of Philmalay until December 31, 1997 only. In a letter dated January 12, 1998, petitioner confirmed his verbal notice of resignation and requested that he be given the same benefits granted to retrenched and resigned employees of the company, consisting of separation pay equivalent to 1 month salary for every year of service and the monetary equivalent of his sick leave and vacation leave.

Respondent Philmalay retrenched petitioner effective January 20, 1998 and promised to pay him separation benefits pursuant to the provisions of the Labor Code. He was, however, offered a separation pay equivalent to four months only. The offer was not accepted by petitioner and efforts to settle the impasse proved futile.

Petitioner filed with the Arbitration Branch of the National Labor Relations Commission a complaint for underpayment of wages and nonpayment of separation pay, sick leave, vacation leave and other benefits against respondents.

The Labor Arbiter rendered a decision in favor of petitioner.

On appeal by respondents to the NLRC, the Decision of the Labor Arbiter was modified.

Undaunted, petitioner filed a petition for certiorari with the Court of Appeals, which was dismissed for failure to attach to the petition the following: “(1) complainant’s (petitioner) Position Paper filed before the Labor Arbiter; (2) Decision dated 22 December 1992 penned by Labor Arbiter Ariel Cadiente Santos; and (3) Memorandum of Appeal filed bythe petitioner.”

Petitioner filed a motion for reconsideration, attaching thereto a copy of the Labor Arbiter’s decision and the pleadings he failed to attach to the petition. The Court of Appeals, however, denied petitioner’s motion for reconsideration. Hence, the instant petition

ISSUE:

Whether or not the CA committed GADALEJ in dismissing the petition based on technicalities

RULING:

The allowance of the petition on the ground of substantial compliance with the Rules is not a novel occurrence in our jurisdiction. As consistently held by the Court, rules of procedure should not be applied in a very technical sense, for they are adopted to help secure, not override, substantial justice.

In Jaro v. Court of Appeals, we applied the rule on substantial compliance because the petitioner amended his defective petition and attached thereto the relevant annexes certified according to the rules.

The same leniency should be applied to the instant case considering that petitioner subsequently submitted with his motion for reconsideration the certified true copy of the Labor Arbiter’s decision, the complainant’s position paper and the respondent’s memorandum of appeal. Clearly, petitioner had demonstrated willingness to comply with the requirements set by the rules. If we are to apply the rules of procedure in a very rigid and technical sense, as the Court of Appeals did in this case, the ends of justice would be defeated.

Labor laws mandate the speedy disposition of cases, with the least attention to technicalities but without sacrificing the fundamental requisites of due process. Remanding the case to the Court of Appeals will only frustrate speedy justice and, in any event, would be a futile exercise, as in all probability the case would end up with this Court.