Case Summary (G.R. No. 164940)
Facts of the Case
Rolando Perez was employed as a fitter by Varorient on the vessel M/V Sparrow. Following the onset of persistent back pains, he was repatriated to the Philippines after a foreign doctor advised he was fit for light work. Upon his return, he was diagnosed with lumbosacral instability, and Varorient covered his physical therapy expenses. However, after completing only ten sessions of therapy, Perez filed a complaint with the National Labor Relations Commission (NLRC) against Varorient, Colarina, and Lagoa for various claims including disability benefits.
Procedural History
The initial decision of Labor Arbiter Antonio Cea dismissed Perez's complaint due to lack of merit. Perez appealed the ruling to the NLRC, which ultimately reversed the Labor Arbiter's decision, stating that Perez had met all necessary requirements under the POEA Standard Employment Contract to claim compensation. Varorient's subsequent motion for reconsideration was denied, prompting them to file a certiorari petition with the Court of Appeals, which was dismissed due to procedural issues regarding representation in the filing.
Issues Before the Court
The Court faced several issues, chiefly whether Varorient had substantially complied with the verification and certification requirements as mandated by the rules governing certiorari petitions, and whether the claims filed against the various defendants (Varorient, Lagoa, and Colarina) could be resolved without independent verification from each party.
Compliance and Authority
The Court of Appeals dismissed Varorient's petition primarily because the verification was signed by an unempowered representative. However, Varorient later provided a Secretary’s Certificate post hoc to support the authority of the signatory, Ma. Luisa C. Isuga.
Ruling on Substantial Compliance
The Supreme Court acknowledged that the failure to submit timely certification could still fall under substantial compliance. As noted in prior rulings, the belated submission of requisite certifications should not bar access to justice, especially when a corporation's management dynamics and board resolutions interconnect its officers' legal responsibilities.
Solidary Liability Under POEA Rules
The ruling also addressed the solidary liability of corporate officers under the POEA Rules, clarifying that Colarina’s liability is intertwined with Varorient’s obligations. Thus, her absence of independent certification did not invalidate the claim against Varorient, as relevant defenses could still be cited collectively by the solidary obligors.
Relevance of the Certification Against Forum Shopping
The Supreme Court highlighted that when a
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Case Background
- The petitioner, Varorient Shipping Co., Inc. (Varorient), filed a petition for review on certiorari under Rule 45 seeking to reverse the Court of Appeals' resolutions dated May 25, 2004, and August 9, 2004.
- Varorient acted on behalf of Lagoa Shipping Corporation (Lagoa) and employed private respondent Rolando M. Perez (Perez) as a fitter on the vessel M/V Sparrow.
- A Contract of Employment was executed on December 2, 1998, and Perez was deployed aboard the vessel.
- Perez began experiencing persistent back pains, leading to treatment by a foreign doctor who deemed him fit for light work only.
- Upon repatriation, Perez was diagnosed with lumbosacral instability and underwent a physical therapy program, which he discontinued after 10 sessions.
- Perez subsequently filed a complaint with the National Labor Relations Commission (NLRC) for disability benefits, illness allowance, and other claims.
Procedural History
- The Labor Arbiter dismissed Perez's case for lack of merit on January 20, 2003.
- Perez appealed to the NLRC, which reversed the Arbiter's decision on October 30, 2003, stating that Perez had complied with the necessary requirements for claiming compensation.
- Varorient's motion for reconsideration was denied, prompting it to file a petition for certiorari and injunction with the Court of Appeals.
Court of Appeals Rulings
- The Court of Appeals dismissed Varorient&