Facts:

The case involves Eureka Personnel and Management Services, Inc. as the petitioner and the National Labor Relations Commission (NLRC) and Apolonio A. Bueno as the respondents. Apolonio A. Bueno was employed by Eureka Personnel and Management Services, Inc. on behalf of its principal, Saudi Archirodon, Ltd., as a mechanic with a monthly salary of SR$1,763. He was deployed on June 14, 1999, but was assigned to work as a carpenter, receiving a reduced salary of SR$750. During his employment, Bueno sustained an injury to his right eyebrow, which required treatment at Gosi Hospital in New Jeddah. Although subsequent examinations indicated that his eyesight was normal, Bueno chose to remain in his quarters and refused to work. He was repatriated on March 21, 2001, and signed a receipt acknowledging the receipt of SR$3,000 from Saudi Archirodon, Ltd. Following his repatriation, Bueno filed a complaint against Eureka for illegal dismissal, non-payment and underpayment of salaries, as...

Facts:

Employment and Deployment:
Private respondent Apolonio A. Bueno was hired by petitioner Eureka Personnel and Management Services, Inc. on behalf of its principal, Saudi Archirodon, Ltd., as a mechanic with a monthly salary of SR$1,763. He was deployed on June 14, 1999, but was made to work as a carpenter with a reduced monthly salary of SR$750.

Injury and Repatriation:
During his employment, Bueno sustained an injury to his right eyebrow and was treated at Gosi Hospital in New Jeddah. Subsequent medical examinations confirmed that his eyes were normal, but he refused to return to work and remained in his quarters. On March 21, 2001, he was repatriated and signed a receipt acknowledging the receipt of SR$3,000 from Saudi Archirodon, Ltd.

Labor Complaint:
Bueno filed a complaint for illegal dismissal, non-payment and underpayment of salaries, and moral and exemplary damages against Eureka Personnel and Management Services, Inc.

Labor Arbiter’s Decision:
On February 28, 2002, the Labor Arbiter ruled in favor of Bueno, ordering the petitioner to pay:

1. SR$5,289 as equivalent to 3 months' salary for the unexpired portion of the contract.
2. SR$9,117 as salary differential for 9 months.

NLRC’s Modification:
On appeal, the National Labor Relations Commission (NLRC) modified the Labor Arbiter’s decision on June 30, 2003, deleting the award of 3 months' salary but awarding salary differentials for the entire 12-month contract period, computed as SR$12,156.

Court of Appeals’ Dismissal:
Petitioner filed a special civil action for certiorari with the Court of Appeals, which dismissed the petition for failure to comply with procedural requirements under Section 1, Rule 65 in relation to Section 3, Rule 46 of the Rules of Court. The appellate court noted the absence of critical documents, such as the complaint for illegal dismissal, medical records, contract of employment, position papers, and the Labor Arbiter’s decision.

Issue:

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Ruling:

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Ratio:

1. Procedural Compliance: The Rules of Court require strict compliance with procedural requirements, including the submission of all relevant documents in a petition for certiorari. Failure to comply is a sufficient ground for dismissal.
2. Materiality of Documents: The missing documents (complaint, contract of employment, position papers, and Labor Arbiter’s decision) were material to resolving the issue of salary differentials, as they provided the factual and legal basis for the claims.
3. Liberal Construction Not Warranted: The Court found no cogent reason to apply liberal construction of the rules in this case, as the petitioner failed to rectify its procedural deficiencies even after being given the opportunity to do so.
4. Substantial Justice: The Court reiterated that while liberal construction of the rules is allowed in certain cases to serve substantial justice, such leniency is not justified when the petitioner fails to show sufficient cause for non-compliance.