GR 223290; (November, 2016) (Digest)
G.R. No. 223290 . November 07, 2016
WOODROW B. CAMASO, PETITIONER, VS. TSM SHIPPING (PHILS), INC., UTKILEN, AND/OR JONES TULOD, RESPONDENTS.
FACTS
Petitioner Woodrow B. Camaso, a seafarer, filed a complaint for disability benefits and other monetary claims against his employers, alleging his tonsillar cancer was work-related. The Labor Arbiter ruled in his favor, but the National Labor Relations Commission (NLRC) reversed the decision and dismissed his complaint. Camaso subsequently filed a petition for certiorari with the Court of Appeals (CA) to challenge the NLRC ruling.
The CA dismissed Camaso’s petition outright due to alleged non-payment of the required docket fees. Camaso moved for reconsideration, arguing that a personal check for payment was attached to his petition but was overlooked by the CA receiving section. The CA denied his motion, upholding the presumption of regularity in its official duties and noting that, even if a check was attached, a personal check is not an authorized mode of payment under the court’s internal rules.
ISSUE
Whether the Court of Appeals correctly dismissed Camaso’s petition for certiorari for non-payment of docket fees.
RULING
The Supreme Court ruled that the CA erred in dismissing the petition. While Section 3, Rule 46 of the Rules of Court mandates dismissal for failure to pay docket fees, this rule is not absolute and may be relaxed to serve substantial justice. The Court emphasized that the primary consideration is whether the claimant demonstrates a willingness to pay and an absence of intent to defraud the government.
Here, the attachment of a personal check, though not a sanctioned mode of payment under the CA’s internal rules, constituted a clear demonstration of Camaso’s good faith and earnest effort to comply with the payment requirement. This fact was corroborated as the check was later found still stapled to the petition. The strict application of procedural technicalities would unjustly deny a review of the substantive merits of his labor case. Consequently, the Supreme Court set aside the CA resolutions and remanded the case to the CA for proper proceedings on the merits, directing Camaso to pay the correct docket fees within a reasonable time.