G.R. No. 142405 - Abapo vs. Court of Appeals

The petitioners are 120 former employees of San Miguel Corporation (SMC), specifically from the Mandaue Brewery Plant.
SMC, a private corporation, initiated a viability study in 1991, which led to the adoption of a modernization program. This program involved installing high-speed, labor-saving machines in the plant, directly affecting the traditional production lines.

As a result of the modernization program, several positions and functions of the employees were declared redundant.
On February 13, 1992, SMC informed the Office of Region VII, Department of Labor and Employment (DOLE) through two letters regarding its decision to terminate the services of the affected employees.
Subsequent notifications were sent on February 7, 1992, and September 28, 1992, promising the employees:

A separation pay amounting to 175% of their respective monthly salaries for every year of service.
A three-year free hospitalization coverage.
Free training and consultation for livelihood programs and small-scale business enterprises.
Assistance in local and overseas job placements.

The employees accepted these terms, executing their respective quitclaims and releases before DOLE's regional officers, thereby formalizing the settlement.

Two years later, the employees initiated separate legal actions by filing complaints with the Labor Arbiter, consolidated under NLRC Cases Nos. RAB VII-11-1175-95 and RAB VII-01-0096-96. Their claims alleged that SMC had not actually instituted a modernization program and that the mass lay-off was illegal.
On November 25, 1996, the Labor Arbiter rendered a decision dismissing the complaints on their merits.
On appeal, the 4th Division of the National Labor Relations Commission (NLRC), in NLRC Case No. V-0099-97, affirmed the dismissal, endorsing the legality of the termination, particularly in view of the modernization program and the binding quitclaims executed by the employees.

Petitioners subsequently sought a review of the NLRC decision by filing a special civil action for certiorari before the Court of Appeals in CA-G.R. SP No. 56726.
The petition was dismissed by the Court of Appeals on two primary grounds:

The petition failed to include a certified true copy of the NLRC Resolution (dated October 29, 1997) which was the subject of the controversy, as required by Rule 46, Section 3 of the 1997 Rules of Civil Procedure.
The petition was filed beyond the reglementary period, being seven (7) days late.

Petitioners contested the dismissal, arguing that the omission was attributable to the voluminous nature of the documents involved and maintained that the dismissal was an abuse of discretion based solely on technical grounds.

Whether the Court of Appeals gravely abused its discretion in dismissing the petition for review on certiorari because:

The petition did not include a certified true copy of the NLRC Resolution, a requirement under Section 3, Rule 46 of the 1997 Rules of Civil Procedure.
The petition was filed seven days past the reglementary period.

Whether the technical non-compliance with the procedural requirements should excuse the merits of the petition, particularly in view of the alleged voluminous nature of the documents involved.