G.R. No. 246439 - PPC Asia Corp. vs. Department of Trade and Industry

On July 22, 2015, Louis “Barok” Biraogo filed a consumer complaint with the DTI–Fair Trade Enforcement Bureau (FTEB) docketed as ADM Case No. CC17-005, naming Pollux Distributors, TPL Industrial Sales, Power Point Battery Mfg. Corp., and PPC Asia Corporation as respondents.
He alleged that between 2013 and 2015, he replaced four lead-acid motorcycle batteries within three months of use. The batteries bore brands 3K, Nagoya, Quantum, and GS Tropical.

Biraogo sought PABMA’s assistance to verify compliance with PNS 06:1987. PABMA engaged Philippine Batteries, Inc. (PBI) to test 24 samples.
PBI found many samples failing the reserve-capacity test, concluding they were substandard. Biraogo prayed for confirmatory tests, a cease-and-desist order, fines, and license cancellations under Sections 50 and 52 of RA 7394 (Consumer Act).

By Decision dated February 14, 2017, DTI–FTEB dismissed the complaint for lack of standing and cause of action, holding that sales receipts did not establish Biraogo as the actual buyer and that prior Bureau of Philippine Standards certifications prevailed.
On appeal, Undersecretary Rowel S. Barba reversed on May 25, 2018, ordered immediate official testing of the batteries, and dispensed with technical rules on sales receipts, finding that Biraogo, as a consumer, was prejudiced.

PPC Asia filed a petition for certiorari in CA-G.R. SP No. 157378.
By Resolution dated October 18, 2018, the Court of Appeals dismissed the petition for failure to attach the complaint, position paper, and appeal memorandum; failure to file a motion for reconsideration; and unauthorized signing of the verification and certification against forum-shopping.
PPC’s motion for reconsideration was denied on March 12, 2019, as no efforts were made to cure the deficiencies.

PPC sought review on certiorari, alleging that the Court of Appeals dismissed on mere technicalities and that DTI violated its due-process rights by reinstating the complaint without hearing.
The DTI opposed, maintaining that the CA correctly dismissed for non-compliance with certiorari requisites and that no due-process violation occurred, as PPC actively participated and may still defend in the administrative case.

Did the Court of Appeals err in dismissing the petition for certiorari on grounds that:

PPC failed to submit the three relevant documents (complaint, position paper, appeal memorandum)?
PPC failed to file a motion for reconsideration of the DTI’s decision?
PPC failed to submit the corresponding authority of its lawyer to sign the verification and certification on non-forum shopping?

Was PPC’s right to due process violated when the DTI required confirmatory testing of its battery brands?