In Michael V. Racion v. MST Marine Services Philippines, Inc., the Supreme Court affirmed the Court of Appeals’ decision to dismiss a petition for certiorari due to the petitioner’s failure to strictly comply with procedural rules. The case underscores the importance of adhering to the Rules of Court, particularly concerning the certificate of non-forum shopping and the accurate indication of parties’ addresses. This ruling reinforces the principle that while justice should be served, procedural requirements are not mere technicalities and must be observed to ensure the orderly administration of justice.

Sailing Against the Wind: When Procedural Missteps Sink a Seafarer’s Claim

The case revolves around Michael V. Racion, a seafarer who sought disability benefits after sustaining an injury during his employment with MST Marine Services Philippines, Inc. After his claim was initially dismissed by the Labor Arbiter (LA), Racion appealed to the National Labor Relations Commission (NLRC), which granted him financial assistance. Dissatisfied, Racion filed a petition for certiorari with the Court of Appeals (CA), questioning the NLRC’s decision. However, the CA dismissed the petition due to procedural defects: the certificate of non-forum shopping was signed by Racion’s counsel without a Special Power of Attorney (SPA), and the petition failed to state the addresses of both Racion and respondent Alfonso Ranjo Del Castillo. The central legal question is whether the CA erred in dismissing the petition for non-compliance with procedural rules, even if it meant potentially overlooking the merits of Racion’s claim.

The Supreme Court (SC) upheld the CA’s decision, emphasizing that certiorari is an extraordinary remedy that demands strict adherence to procedural rules. The Court reiterated the principle established in Vda. De Formoso v. Philippine National Bank, stating that “[c]ertiorari is an extraordinary, prerogative remedy and is never issued as a matter of right. Accordingly, the party who seeks to avail of it must strictly observe the rules laid down by law.” The SC underscored that the acceptance of a petition for certiorari is within the court’s discretion, particularly when procedural errors, such as violations of the Rules of Court, are present.

One of the critical procedural lapses in this case was the defective certificate of non-forum shopping. Section 3, Rule 46 of the Rules of Court explicitly requires the petitioner to submit a sworn certification attesting that they have not commenced any other action involving the same issues in other tribunals or agencies. The rule states:

SEC. 3. Contents and filing of petition; effect of non-compliance with requirements. — The petition shall also submit together with the petition a sworn certification that he has not theretofore commenced any other action involving the same issues in the Supreme Court, the Court of Appeals or different divisions thereof, or any other tribunal or agency; if there is such other action or proceeding, he must state the status of the same…The failure of the petitioner to comply with any of the foregoing requirements shall be sufficient ground for the dismissal of the petition.

In this instance, Racion’s counsel signed the certification without proper authorization, which the Court deemed a fatal defect. This ruling aligns with the precedent set in Suzuki v. de Guzman, where the SC affirmed the dismissal of a petition because the certificate was signed by counsel instead of the petitioners themselves. The Court emphasized that the attestation in the certification requires personal knowledge by the party executing it.

Further compounding the procedural issues, Racion failed to comply with the requirement to indicate the actual addresses of all petitioners and respondents. The SC referenced Cendaña v. Avila, which firmly established that the inclusion of actual addresses in a petition for certiorari is mandatory, and failure to comply is sufficient ground for dismissal.

Racion’s plea for a liberal application of the rules was rejected by the Court, which found no compelling justification for overlooking the procedural deficiencies. The Court emphasized that procedural rules are not mere technicalities and should be followed, except in the most persuasive of circumstances. Even if the Court were to disregard these technical defects, Racion failed to provide the decisions of the NLRC and LA, which are necessary for reviewing their findings.

The Supreme Court’s decision underscores the critical importance of complying with procedural rules in Philippine courts. The Court in Indoyon, Jr. v. Court of Appeals, illuminated the potential consequences of disregarding procedural rules and the message it would send to lower courts:

We emphasize that an appeal is not a matter of right, but of sound judicial discretion. Thus, an appeal may be availed of only in the manner provided by law and the rules. Failure to follow procedural rules merits the dismissal of the case, especially when the rules themselves expressly say so, as in the instant case. While the Court, in certain cases, applies the policy of liberal construction, this policy may be invoked only in situations in which there is some excusable formal deficiency or error in a pleading, but not when the application of the policy results in the utter disregard of procedural rules, as in this case.

We dread to think of what message may be sent to the lower courts if the highest Court of the land finds fault with them for properly applying the rules. That action will surely demoralize them. More seriously, by rendering for naught the rules that this Court itself has set, it would be undermining its own authority over the lower courts.

The Racion case reaffirms the established principle that procedural rules are essential for the orderly and efficient administration of justice. While the pursuit of substantive justice is paramount, it cannot come at the expense of disregarding the rules of procedure, which are designed to ensure fairness and predictability in legal proceedings.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals (CA) erred in dismissing the petition for certiorari outright due to the petitioner’s failure to comply with procedural requirements, specifically regarding the certificate of non-forum shopping and the indication of parties’ addresses.
Why was the petition dismissed by the Court of Appeals?	The CA dismissed the petition because the certificate of non-forum shopping was signed by the petitioner’s counsel without proper authorization (Special Power of Attorney), and the petition failed to include the actual addresses of the petitioner and one of the respondents.
What is a certificate of non-forum shopping, and why is it important?	A certificate of non-forum shopping is a sworn statement by the petitioner confirming that they have not commenced any other action involving the same issues in other tribunals or agencies. It is important to prevent parties from simultaneously pursuing the same case in multiple venues, thereby avoiding conflicting decisions and promoting judicial efficiency.
Can a lawyer sign the certificate of non-forum shopping on behalf of the client?	Generally, no. The Supreme Court has ruled that the attestation in the certification requires personal knowledge by the party executing it. Unless the lawyer has a Special Power of Attorney (SPA) and can demonstrate clear and valid reasons, the certificate must be signed by the petitioner.
What does the Supreme Court say about the importance of procedural rules?	The Supreme Court emphasizes that procedural rules are not mere technicalities and must be strictly observed. While the pursuit of substantive justice is important, it cannot come at the expense of disregarding the rules of procedure, which are designed to ensure fairness and predictability in legal proceedings.
Is there any room for liberal interpretation of the rules?	The Court may allow a liberal interpretation of the rules in situations where there is a justifiable cause for non-compliance, but not when the application of the policy results in the utter disregard of procedural rules. A mere claim of inadvertence is not a weighty reason to relax the application of the rules.
What was the basis for the Supreme Court’s decision in this case?	The Supreme Court based its decision on the petitioner’s failure to strictly comply with procedural rules, particularly the requirements for the certificate of non-forum shopping and the indication of parties’ addresses. The Court emphasized that certiorari is an extraordinary remedy that demands strict adherence to the Rules of Court.
What happens if a party fails to provide the actual addresses of all petitioners and respondents in the petition?	Failure to provide the actual addresses of all petitioners and respondents is sufficient ground for the dismissal of the petition. The Supreme Court has deemed this requirement mandatory.
What documents should be attached to the Petition for Certiorari?	Even if technical defects are glossed over, the petitioner should have attached the decisions of the NLRC and LA as they are necessary for reviewing their findings.

The Michael V. Racion case serves as a reminder to legal practitioners and litigants alike about the significance of adhering to procedural rules in Philippine courts. Overlooking these rules, even with the best intentions, can have detrimental consequences on the outcome of a case. The meticulous compliance with court procedures ensures a fair and orderly legal process, upholding the integrity of the justice system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Michael V. Racion v. MST Marine Services Philippines, Inc., G.R. No. 219291, July 04, 2018