G.R. No. 149634 - Torres vs. Specialized Packaging Development Corp.

Petitioners are former employees of the Specialized Packaging Development Corporation (SPDC), a company engaged in repackaging cosmetic products.
They filed three separate complaints alleging illegal dismissal and nonpayment of benefits (overtime, premium pay, 13th month pay, and night differential).
The initial complaint was heard by Labor Arbiter (LA) Salimathar Nambi, who rendered decisions in favor of the petitioners.

The first LA decision (June 30, 1995) ruled in favor of the petitioners due to the failure of the respondents to submit their respective position papers on or before the deadline.
SPDC appealed to the National Labor Relations Commission (NLRC), which set aside the LA decision and remanded the case for further proceedings.
A second LA decision (December 14, 1999) again found in favor of the petitioners regarding their illegal termination.
The NLRC reversed this new decision on June 9, 2000, prompting petitioners to elevate the matter to the Court of Appeals (CA) on January 29, 2001.
Two CA Resolutions were issued:

The January 15, 2001 resolution dismissed the petition for a defective or insufficient verification and certification against forum shopping.
The August 28, 2001 resolution denied the petitioners’ Motion for Reconsideration.

Of the twenty-five principal petitioners, only two (Evelyn Dolom and Criselina Anquilo) executed the required verification and certification against forum shopping.
The CA maintained that all 25 petitioners were mandated to sign the verification and certification in order to strictly comply with the procedural rules, specifically:

The CA reasoned that a lone or partial signature could allow some petitioners to pursue parallel actions, thereby defeating the purpose of the certification.
Petitioners argued that justifiable causes—such as logistical difficulties, long delays caused by the remand to the labor arbiter, and geographical constraints—prevented the complete execution of the certification and that technical strictness should yield to the interests of substantial justice.

In addition to the technical deficiency, petitioners raised substantive issues concerning:

Petitioners asserted that the conflicting determinations of the LA and NLRC regarding their employment merits warranted a proper review by the CA rather than outright dismissal based solely on a technicality.

Whether it is acceptable, under the doctrine of substantial compliance, for only two of the twenty-five petitioners to execute the verification under Section 4 of Rule 7.
Whether the same standard of substantial compliance can apply to the certification against forum shopping required under Section 5 of Rule 7, despite the fact that not all petitioners signed.

Whether petitioners are indeed employees of the Specialized Packaging Development Corporation (SPDC).
Whether the petitioners were illegally dismissed by SPDC.
Whether the petitioners are entitled to money claims such as back wages, premium pay for holidays and rest days, service incentive leave pay, and 13th month pay.

Whether strict enforcement of verification and certification requirements should prevail over the need to avoid a miscarriage of justice by barring a meritorious appeal.
Whether the failure of some petitioners to personally sign the certification against forum shopping violates due process by denying the respondents a fair opportunity to comment on all raised issues.