Facts:

The case involves Joselito Ma. P. Jacinto, the former president of F. Jacinto Group, Inc., as the petitioner, and Edgardo Gumaru, Jr. as the respondent. The events leading to this case began on December 6, 2004, when a decision was rendered in favor of Gumaru in NLRC-NCR Case No. 00-06-07542-03, ordering Jacinto and his company to pay various monetary claims, including separation pay, unpaid wages, and damages, totaling over P1,000,000.00. Jacinto and his company appealed the decision to the National Labor Relations Commission (NLRC), but their appeal was dismissed due to their failure to post the required cash or surety bond, rendering the December 6, 2004 decision final and executory as of November 23, 2005. A Writ of Execution was issued on February 6, 2006, leading to the levy of Jacinto's property in Baguio City for auction. Jacinto filed an Extremely Urgent Motion to Lift and Annul the Levy on Execution on June 20, 2008, which was denied by the Labor Ar...

Facts:

Labor Case Decision

• On December 6, 2004, the Labor Arbiter rendered a decision in favor of respondent Edgardo Gumaru, Jr., holding petitioner Joselito Ma. P. Jacinto and F. Jacinto Group, Inc. jointly and severally liable for various monetary claims, including separation pay, unpaid wages, moral damages, exemplary damages, and attorney’s fees. The total amount awarded was substantial, with legal interest accruing from September 1, 2000.

Failure to Perfect Appeal

• Petitioner and F. Jacinto Group, Inc. attempted to appeal the decision to the National Labor Relations Commission (NLRC). However, the appeal was not perfected due to their failure to post the required cash or surety bond. As a result, the December 6, 2004 decision became final and executory, and an entry of judgment was issued on November 23, 2005.

Execution of Judgment

• A Writ of Execution was issued on February 6, 2006, and a Second Alias Writ of Execution was later issued. Real property owned by petitioner in Baguio City was levied upon and scheduled for auction sale on June 27, 2008.

Motion to Lift Levy

• On June 20, 2008, petitioner filed an Extremely Urgent Motion to Lift and Annul Levy on Execution, arguing that the writ of execution had already expired. The Labor Arbiter denied the motion, ruling that the writ had a life of five years and ordering the auction sale to proceed.

NLRC Resolution

• Petitioner appealed the Labor Arbiter’s order to the NLRC, which, in a November 28, 2008 resolution, set aside the Labor Arbiter’s order and granted petitioner’s motion to lift the levy. The NLRC remanded the case to the Labor Arbiter for further execution proceedings.

Court of Appeals Proceedings

• Petitioner filed a Petition for Certiorari with the Court of Appeals (CA), challenging the NLRC’s resolutions. However, the CA dismissed the petition due to a defective verification and certification against forum shopping, which was signed by petitioner’s counsel instead of petitioner himself.

Satisfaction of Judgment

• Respondent later informed the Supreme Court that the judgment award had been fully satisfied, rendering the case moot and academic.

Issue:

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Ruling:

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Ratio:

1. Verification and Certification Against Forum Shopping: The Court reiterated that while verification and certification against forum shopping are important procedural requirements, they are not jurisdictional. Defects in these requirements may be excused under reasonable or justifiable circumstances, such as when a party is unable to sign due to being abroad or physically incapacitated. In such cases, a special power of attorney authorizing counsel to sign on behalf of the party may suffice.

2. Mootness of the Case: The Court emphasized that once a judgment has been fully satisfied, the case is deemed terminated, and no further proceedings are necessary. Satisfaction of the judgment renders the case moot and beyond the Court’s review. This principle ensures finality and closure in legal disputes.

3. Finality of Judgments: The Court highlighted the importance of finality in judgments, noting that a judgment debtor who voluntarily complies with a judgment is estopped from appealing it. This principle promotes judicial efficiency and prevents unnecessary litigation.

Conclusion:

The Supreme Court denied the petition, holding that the satisfaction of the judgment award rendered the case moot and academic. The Court also clarified the rules on verification and certification against forum shopping, emphasizing that while these requirements are important, they are not jurisdictional and may be excused under reasonable circumstances.