G.R. No. 240084 - Oliveros vs. Court of Appeals

Petitioners Ruben O. Oliveros and Homer Henry S. Sanchez filed a Petition for Certiorari under Rule 65 of the Rules of Court.
They sought to set aside the Court of Appeals’ Resolution dismissing their previous petition for certiorari.
The petition challenges procedural defects, a violation of Rule 65, and noncompliance with specific CA resolutions.

While employed at First Laguna Electric Cooperative (FLECO) as a distribution system analyst and system planning and design engineer, petitioners were alleged to have a conflict of interest.
They were accused of having business interests in Sergio Paulo Contractor Services—an accredited contractor performing electrical work for FLECO—through ownership ties and associated roles.
An anonymous text message, received by FLECO, alleged that petitioners were involved in activities not permitted within an electric cooperative.

In response to the text message, FLECO’s Officer-in-Charge, Ramil F. De Jesus, issued a memorandum on April 30, 2015, inquiring about any conflict between the petitioners’ personal business and FLECO’s interests.
Accompanying the memorandum were documents such as Sergio Paulo’s organizational chart and its accomplishments, which served as evidence of a conflict of interest.
Petitioners submitted a Second Explanation Letter denying any conflict, contending that actions based on an anonymous text lacked due process, and asserting the need for a sworn complaint and the right to cross-examine the complainant.

On May 27, 2015, additional memoranda were issued along with sworn statements by the company’s managers, confirming the alleged business tie with Sergio Paulo.
A Housewiring Report was also introduced, which purportedly indicated that petitioners had inspected the work done by Sergio Paulo.
In their Explanation, petitioners argued that such sworn statements were hearsay since those who executed them did not have direct knowledge of the matters.

Following a hearing on June 26, 2015, and recommendations by the Grievance Committee, FLECO terminated the petitioners’ employment effective July 31, 2015.
Petitioners then filed a case for illegal dismissal and money claims against FLECO and members of the Grievance Committee.
The Labor Arbiter (LA) initially ruled in favor of petitioners, citing a violation of due process, and ordered their reinstatement along with backwages and various damages.
However, on appeal, the National Labor Relations Commission (NLRC) reversed the LA’s decision, ruling that petitioners were given notice and opportunity to be heard, and that their termination was justified based on the conflict of interest.

Petitioners filed a Rule 65 Petition for Certiorari in the Court of Appeals (CA) contesting the dismissal of their certiorari petition.
The CA had earlier issued resolutions (dated September 22, 2016, and February 8, 2017) directing petitioners to submit material portions of the record, as mandated by Section 3, Rule 46 in relation to Rule 65.
Despite petitioners filing a manifestation and an urgent motion for extension (requesting an additional 30 days), they failed to submit key documents (such as the Organizational Chart of Sergio Paulo, its list of accomplishments, and the Statement of Account and Material Costing).
Consequently, on October 27, 2017, the CA dismissed the petition for certiorari on the grounds of formal defects and noncompliance.
On April 13, 2018, the CA denied petitioners’ Motion for Reconsideration, prompting the present petition challenging the CA’s dismissal.

Whether the Court of Appeals committed grave abuse of discretion in dismissing the petition for certiorari on the basis of formal defects and noncompliance with its resolutions.
Whether petitioners’ chosen remedy (a petition for certiorari under Rule 65) was proper in light of the availability of an appeal under Rule 45 of the Rules of Court.
Whether the failure to submit material portions of the record—in particular, the documents relied upon by the NLRC—justifies the dismissal of the certiorari petition.