In Felix Martos, et al. v. New San Jose Builders, Inc., the Supreme Court addressed the crucial role of verification in labor disputes. The Court ruled that complaints filed by numerous employees were rightly dismissed due to their failure to properly verify their position papers. This decision underscores the importance of adhering to procedural rules, specifically the requirement for proper verification, to ensure the truthfulness and good faith of allegations presented before labor tribunals.

When a Signature Speaks Volumes: The Case of Unverified Labor Claims

This case arose from a labor dispute involving Felix Martos and a large group of other complainants against New San Jose Builders, Inc. (NSJBI). These individuals claimed illegal dismissal and sought various monetary claims. The core issue revolved around whether the failure of most of the complainants to verify their position papers was a fatal procedural flaw, warranting the dismissal of their claims, and whether Martos, who did verify his claims, was entitled to reinstatement.

The factual backdrop reveals that NSJBI, engaged in construction, faced financial constraints, leading to workforce adjustments. The complainants, former employees, alleged illegal dismissal, while NSJBI contended they were project employees whose employment ended with project completion. Initially, the Labor Arbiter (LA) ruled in favor of Felix Martos but dismissed the claims of the others without prejudice. The National Labor Relations Commission (NLRC) later reversed this decision, ordering the reinstatement of all complainants. However, the Court of Appeals (CA) overturned the NLRC’s ruling, reinstating the LA’s original decision. This led to the Supreme Court appeal, focusing on the significance of verification and the appropriateness of reinstatement.

The Supreme Court emphasized the importance of verification as a requirement under Sections 4 and 5 of Rule 7 of the 1997 Rules of Civil Procedure. The Court quoted:

SEC. 4. Verification. – Except when otherwise specifically required by law or rule, pleadings need not be under oath, verified or accompanied by affidavit.

A pleading is verified by an affidavit that the affiant has read the pleadings and that the allegations therein are true and correct of his personal knowledge or based on authentic records.

A pleading required to be verified which contains a verification based on “information and belief” or upon “knowledge, information and belief” or lacks a proper verification, shall be treated as an unsigned pleading.

The Court further stated that, “The verification requirement is significant, as it is intended to secure an assurance that the allegations in the pleading are true and correct and not the product of the imagination or a matter of speculation, and that the pleading is filed in good faith.” This requirement ensures that allegations are made responsibly and in good faith. The Court noted that the absence of proper verification could be a ground for treating the pleading as unsigned and, consequently, dismissible.

Building on this principle, the Court highlighted that while Martos had signed the verification, there was no evidence that he was authorized to represent the other complainants. The court cited Nellie Vda. De Formoso v. PNB, where similar circumstances led to the dismissal of claims due to the lack of authorization. Without proper authorization, Martos’s signature could not validate the claims of the other petitioners.

The Court also addressed the principle of liberal construction of rules, noting that it could be invoked where there is an excusable formal deficiency, but not when it subverts the essence of the proceeding. Despite the dismissal being without prejudice, the complainants failed to rectify the procedural mistake, even during their appeal to the NLRC. As the court stated:

Considering that the dismissal of the other complaints by the LA was without prejudice, the other complainants should have taken the necessary steps to rectify their procedural mistake after the decision of the LA was rendered. They should have corrected this procedural flaw by immediately filing another complaint with the correct verification this time. Surprisingly, they did not even attempt to correct this technical blunder. Worse, they committed the same procedural error when they filed their appeal with the NLRC.

This inaction was deemed negligence, preventing the Court from intervening on their behalf. The court emphasized that labor laws are meant to protect employees but should not excuse a complete disregard for procedural rules. The Court suggested that there was likely some truth to the respondent’s claim that those who failed to sign the verification were either not employees or had simply abandoned their claims.

Turning to Martos’s case, the Court acknowledged that reinstatement was no longer viable due to the strained relationship between the parties. The Court has held:

The accepted doctrine is that separation pay may avail in lieu of reinstatement if reinstatement is no longer practical or in the best interest of the parties. Separation pay in lieu of reinstatement may likewise be awarded if the employee decides not to be reinstated.

Under the doctrine of strained relations, the payment of separation pay is considered an acceptable alternative to reinstatement when the latter option is no longer desirable or viable. On one hand, such payment liberates the employee from what could be a highly oppressive work environment. On the other hand, it releases the employer from the grossly unpalatable obligation of maintaining in its employ a worker it could no longer trust.

The issue of strained relations was raised late in the proceedings, but the Court considered it valid to award separation pay, along with full backwages, 13th-month pay, service incentive leave pay, and attorney’s fees.

FAQs

What was the key issue in this case?	The key issue was whether the failure of most complainants to verify their position papers warranted the dismissal of their claims, and whether Felix Martos, who did verify his claims, was entitled to reinstatement.
Why was verification so important in this case?	Verification ensures that the allegations in a pleading are true and correct, made in good faith, and not speculative. It is a procedural requirement designed to prevent the filing of frivolous claims.
What happens if a pleading lacks proper verification?	A pleading lacking proper verification can be treated as unsigned and is subject to dismissal. This is because verification confirms the truthfulness and authenticity of the claims being made.
Can one person verify a pleading on behalf of many others?	Yes, but only if they are duly authorized to do so. In this case, Felix Martos’s verification was insufficient for the other complainants because there was no proof he was authorized to represent them.
What is the principle of liberal construction of rules?	The principle of liberal construction allows for some leniency in the application of procedural rules, provided it does not undermine the essence of the proceedings. It is meant to facilitate justice, not obstruct it.
Why wasn’t the principle of liberal construction applied to the unverified claims?	Because the complainants failed to correct the procedural defect even after being given the opportunity to do so. Their inaction constituted negligence and disregard for the rules.
What is the doctrine of strained relations?	The doctrine of strained relations allows for the payment of separation pay in lieu of reinstatement when the relationship between the employer and employee has become too damaged. It prevents a hostile work environment.
Why was Felix Martos not reinstated in this case?	Although Martos was found to be illegally dismissed, the Court determined that reinstatement was no longer practical due to the strained relations between him and NSJBI. Separation pay was deemed more appropriate.

The Supreme Court’s decision in this case serves as a reminder of the importance of complying with procedural rules, especially the verification requirement, in labor disputes. While labor laws are designed to protect workers, adherence to proper procedure is essential for ensuring fairness and accuracy in legal proceedings. This ruling provides clarity on the consequences of failing to verify pleadings and the circumstances under which separation pay may be awarded in lieu of reinstatement.

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: Felix Martos, et al. v. New San Jose Builders, Inc., G.R. No. 192650, October 24, 2012