GR 142405; (September, 2004) (Digest)
G.R. No. 142405 ; September 30, 2004
FAUSTINO ABAPO, ET AL., petitioners, vs. THE COURT OF APPEALS and SAN MIGUEL CORPORATION, respondents.
FACTS
The petitioners are 120 former employees of San Miguel Corporation’s (SMC) Mandaue Brewery Plant. In 1991, SMC implemented a modernization program, introducing high-speed machines that rendered several functions redundant. Consequently, SMC terminated the affected employees in 1992, offering them a separation package equivalent to 175% of their monthly salary per year of service, along with other benefits. The employees accepted the benefits and executed quitclaims before the DOLE.
Two years later, the employees filed complaints for illegal dismissal, arguing the modernization program was not genuine. The Labor Arbiter dismissed their complaints, a decision affirmed by the National Labor Relations Commission (NLRC). The petitioners then filed a petition for certiorari with the Court of Appeals.
ISSUE
Whether the Court of Appeals gravely abused its discretion in dismissing the petitioners’ special civil action for certiorari.
RULING
No, the Court of Appeals did not commit grave abuse of discretion. The dismissal was justified on two procedural grounds under Rule 46 of the Rules of Court. First, the petitioners failed to attach a certified true copy of the assailed NLRC Resolution to their petition, a mandatory requirement under Section 3, Rule 46, for which non-compliance is a sufficient ground for dismissal. The Court rejected counsel’s excuse of voluminous records, emphasizing the duty of diligence in organizing pleadings.
Second, the petition was filed seven days beyond the reglementary period, a delay admitted by the petitioners themselves. The rules on periods are mandatory and jurisdictional. Even assuming the petition was procedurally sound, the Supreme Court found it dismissible on substantive grounds, citing a prior case involving the same SMC modernization program which upheld the termination as a valid exercise of management prerogative due to the installation of labor-saving devices. The executed quitclaims were also deemed binding as reasonable settlements. Therefore, the appellate court’s dismissal was proper.