In labor cases, rules of procedure should not be applied in a very rigid and technical sense. They are merely tools designed to facilitate the attainment of justice, and where their strict application would result in the frustration rather than promotion of substantial justice, technicalities must be avoided. Technicalities should not be permitted to stand in the way of equitably and completely resolving the rights and obligations of the parties. Where the ends of substantial justice shall be better served, the application of technical rules of procedure may be relaxed. In certain cases, leniency was granted in the observance of rules of procedure to advance substantial justice. After all, cases should be determined on the merits, after the parties have been given full opportunity to ventilate their causes and defenses, rather than on technicality or procedural imperfection.1Tres Reyes v. Maxim’s Tea House, G.R. No. 140853, February 27, 2003; Malixi v. Baltazar, G.R. No. 208224, November 22, 2017; Jaro v. Court of Appeals, G.R. No. 127536, February 19, 2002, 427 PHIL 532-549
The Supreme Court remanded a certain case to the Court of Appeals, and directed it to reinstate and take action on the Petition for Certiorari filed by the employees. Record revealed that the Court of Appeals had previously dismissed the said petition for having been filed beyond 60 days from notice, based on the employees’ own allegations therein.
Leniency was afforded the employees since they were able to prove that their Petition for Certiorari was actually filed within the reglementary period and the error was merely in the statement of material dates in the said petition. Specifically, the employees were able, albeit belatedly, to append to their Petition for Review on Certiorari a copy of the Bailiff’s Return dated 4 October 2018, which indicated that the Resolution of the National Labor Relations Commission was received by the employees’ counsel on 3 October 2018 (and not 25 September 2018, as erroneously stated by the employees in their Petition for Certiorari). Thus, the Supreme Court found that the Petition for Certiorari filed before the Court of Appeals on 3 December 2018 was filed on time. However, the Court reminded the employees and their counsel to be more circumspect in the indication of material dates and other factual matters in their pleadings to avoid any confusion and to prevent delay. The Court further warned them that other procedural missteps will not be granted the same leniency.
Further reading:
- San Felipe v. Armscor Global Defense, Inc., G.R. No. 247639, January 15, 2020.
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