THE COURT OF APPEALS COMMITTED SERIOUS ERROR IN
AFFIRMING THE LABOR ARBITERS AWARD OF SICKNESS
ALLOWANCE/WAGES WITHOUT ANY LEGAL AND/OR FACTUAL
BASIS.[11]
Simply put, the issues are: (1) Did the Court of Appeals err in treating Suganobs
petition as one filed under Rule 65?; (2) Is Suganob entitled to disability
benefits?; and (3) Is Suganob entitled to sickness allowance/wages?
On the first issue, petitioners contend that Suganobs petition before the Court of
Appeals should have been dismissed outright since he availed of the wrong
remedy. They stress that in the case of St. Martin Funeral Home v. NLRC,[12] the
Court held that decisions of the NLRC should be brought to the Court of Appeals
by way of a petition for certiorari under Rule 65.[13]
For his part, Suganob avers that technical rules of procedure should not be
strictly applied in labor cases. He argues that the Court of Appeals acted
accordingly when it decided the case based on the issues raised and not through
a mere technicality. Further, Suganob asserts that the kind of pleadings filed
before the Court is not determined by its title but rather by its content.
Petitioners contention lacks merit. The policy of our judicial system is to
encourage full adjudication of the merits of an appeal.Procedural niceties should
be avoided in labor cases as the provisions of the Rules of Court are applied
only in a suppletory manner.Indeed, rules of procedure may be relaxed to
relieve a party of an injustice not commensurate with the degree of
noncompliance with the process required.[14] Moreover, averments in the
pleadings, not the title, are controlling[15] in determining the nature of the
proceeding.
Suganob categorized his petition before the Court of Appeals as a petition for
review on certiorari (under Rule 43 of the Revised Rules of Civil
Procedure). However, the contents of his petition clearly reveal that the petition
filed complied with the requirements of a petition for certiorari, albeit wrongly
captioned as one for a petition for review under Rule 43. Courts look beyond
the form and consider substance as circumstances warrant. Thus, we rule that
the Court of Appeals correctly treated Suganobs petition under Rule 43 as one
being filed under Rule 65.