In the case of *Pfizer Inc. v. Galan*, the Supreme Court addressed the importance of adhering to procedural rules, particularly regarding the timeliness of filing petitions for certiorari and the proper verification of pleadings. The Court emphasized that while procedural rules should be liberally construed to promote substantial justice, compliance with mandatory periods and verification requirements is essential. Ultimately, the Court remanded the case to the Court of Appeals, underscoring the retroactive application of amendments to procedural rules and the acceptability of verification by a company specialist with direct knowledge of the case.

When Can Ignorance of Procedure Undermine Justice?

The case originated from an illegal dismissal complaint filed by Edwin V. Galan against Pfizer, Inc., where he was previously employed. After the Labor Arbiter ruled in Galan’s favor, Pfizer appealed to the NLRC, which affirmed the Arbiter’s decision. Pfizer then filed a petition for certiorari with the Court of Appeals, seeking to overturn the NLRC’s resolutions. The Court of Appeals initially dismissed the petition, citing that it was filed beyond the 60-day reglementary period and that the verification of the petition was improperly executed. Pfizer contested this dismissal, arguing that their counsel relied on the original provision of Section 4, Rule 65 of the 1997 Rules of Civil Procedure, and that the verification was sufficient.

The central legal question revolved around the timeliness of the petition for certiorari and the validity of its verification. The petitioners argued that the amended rule regarding the period to file a petition for certiorari was not widely disseminated and that their counsel’s reliance on the original rule constituted an excusable mistake. They also contended that the verification by an Employment Specialist of Pfizer, Inc., who had direct knowledge of the case, should be deemed sufficient compliance with the rules. The Supreme Court had to determine whether to apply the amended rule retroactively and whether the verification met the required standards.

The Supreme Court addressed the issue of the timeliness of the petition by considering the retroactive application of amendments to procedural rules. The Court cited *Systems Factors Corporation v. NLRC*, stating that amendments introduced under A.M. No. 00-2-03-SC are procedural and remedial in character and can be applied retroactively. This amendment allows the filing of a petition for certiorari within sixty days from notice of the denial of a motion for reconsideration. Because Pfizer filed its petition within this period, the Court held that the filing was timely. This demonstrates the principle that procedural laws may be given retroactive effect to actions pending and undetermined at the time of their passage, provided that no vested rights are impaired.

The Court then considered the issue of verification. It acknowledged that a petition for review filed under Rule 65 must be verified, as stated in Section 1, Rule 65 of the 1997 Rules of Civil Procedure. The purpose of verification, as stated in Section 4, Rule 7, is to assure that the allegations in the pleading are made in good faith and are true and correct.

>A pleading is verified by an affidavit that the affiant has read the pleading and that the allegations therein are true and correct his knowledge and belief.

However, the Court also recognized that a lack of verification is generally a formal defect that is neither jurisdictional nor fatal. Citing *Robern Dev’t. Corp. v. Quitain*, the Court noted that it could order the correction of the pleading or act on the unverified pleading if strict compliance with the rule may be dispensed with to serve the ends of justice. In this case, the Court found that the verification by Ms. Cleofe R. Legaspi, an Employment Specialist of Pfizer, Inc., served the purpose of verification because she had direct knowledge of the administrative charges against Galan. The Court noted that Pfizer, as a corporate entity, could only act through its officers, and Ms. Legaspi was acting on behalf of Pfizer when she signed the verification.

In essence, the Court balanced the need for procedural compliance with the principle of substantial justice. The Court underscored that the retroactive application of procedural amendments should be considered, and that verification requirements should be interpreted in light of their purpose, especially when the verifying party has direct knowledge of the facts. This approach contrasts with a rigid adherence to procedural technicalities, which could undermine the pursuit of justice. This decision emphasizes the Court’s role in ensuring that procedural rules facilitate, rather than obstruct, the fair resolution of disputes.

The ruling also highlights the importance of understanding and adhering to the most current procedural rules. Counsel must remain informed about amendments to the rules of procedure to avoid the risk of having their petitions dismissed for technical reasons. The Court’s willingness to apply procedural amendments retroactively provides some flexibility, but it does not excuse a failure to stay updated on the rules. Moreover, this case clarifies that corporations can act through officers with sufficient knowledge of the facts, and their verifications can be deemed compliant with the rules.

By remanding the case to the Court of Appeals, the Supreme Court directed the lower court to proceed with a substantive review of the merits of Pfizer’s petition. This action underscores the Court’s commitment to ensuring that cases are decided on their merits, rather than being dismissed on technicalities. Ultimately, the decision serves as a reminder that procedural rules are intended to facilitate justice, and courts should strive to interpret and apply them in a way that promotes the fair and efficient resolution of disputes.

FAQs

What was the key issue in this case?	The key issues were the timeliness of filing a petition for certiorari and the validity of the verification of the petition. The Court addressed whether the amended rules regarding the filing period should be applied retroactively and whether the verification by a company specialist was sufficient.
What did the Court decide regarding the timeliness of the petition?	The Court decided that the amended rule, which allows filing within sixty days from notice of the denial of a motion for reconsideration, should be applied retroactively. Since Pfizer filed its petition within this period, it was deemed timely.
Was the verification of the petition considered valid?	Yes, the Court considered the verification by Ms. Cleofe R. Legaspi, an Employment Specialist with direct knowledge of the case, as valid. The Court reasoned that she was acting on behalf of Pfizer and had sufficient knowledge to verify the allegations.
What is the purpose of verifying a pleading?	Verification assures that the allegations in the pleading are made in good faith and are true and correct. It serves to prevent frivolous or speculative claims.
What happens if a pleading lacks proper verification?	Generally, lack of verification is a formal defect that is not jurisdictional or fatal. The court may order the correction of the pleading or act on the unverified pleading if strict compliance may be dispensed with to serve justice.
What is the significance of the retroactive application of procedural rules?	Retroactive application means that new procedural rules can apply to pending cases, provided that no vested rights are impaired. This allows courts to apply the most current rules to promote fairness and efficiency.
Why was the case remanded to the Court of Appeals?	The case was remanded because the Supreme Court found that the Court of Appeals had erred in dismissing the petition based on procedural grounds. The Supreme Court directed the Court of Appeals to review the merits of Pfizer’s petition.
What is the broader implication of this case for labor disputes?	The case underscores the importance of staying informed about current procedural rules and the willingness of courts to prioritize substantive justice over strict procedural compliance, especially when verification is made by an authorized representative.

In conclusion, *Pfizer Inc. v. Galan* reaffirms the judiciary’s commitment to balancing procedural compliance with the broader interests of justice. By retroactively applying amended procedural rules and accepting verification from a knowledgeable company specialist, the Supreme Court ensured that the case could be decided on its merits. This decision serves as a reminder of the importance of staying updated on procedural rules and the courts’ discretion in applying them to achieve a just outcome.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Pfizer Inc. v. Galan, G.R. No. 143389, May 25, 2001