Vivo v. Bautista
REITERATIONFacts
The Antecedents: Juliana Vivo filed a complaint against Mariano San Buenaventura and his sister Irene for the delivery of 35 cans of palay harvested from her land. The San Buenaventuras, in turn, filed a claim against Vivo for the same quantity of palay before the Tenancy Law Enforcement Division of the Department of Justice. The latter's claim was dismissed due to the repeated non-appearance of the claimants (the San Buenaventuras). Procedural History: The dismissal order from the Department of Justice was appealed, leading to the elevation of the case to the Court of Industrial Relations (CIR), where it was docketed as Case No. 398-R. The CIR granted the parties 15 days to submit their respective memoranda. After considering the memoranda and evidence, the CIR issued a decision on March 22, 1949, ordering Vivo to return 20% of the palay to complete the share of San Buenaventura as a tenant, and for him to continue as such in the future. The Petition: Juliana Vivo filed a petition for certiorari with the Supreme Court, seeking to nullify the CIR decision. She argued that the CIR decision was void because it was signed by only one member and lacked the concurrence of at least three members, contrary to Commonwealth Act No. 103. She also contended that the CIR did not acquire jurisdiction over her person as she did not appear personally or in writing. Furthermore, she claimed the decision was not supported by evidence and was contrary to law. She received a copy of the decision on April 1, 1949, and filed a motion for reconsideration on April 8, 1949, which was denied on May 26, 1948.
Issue(s)
Whether the decision of the Court of Industrial Relations is null and void for being signed by only one member. Whether the Court of Industrial Relations acquired jurisdiction over the person of the petitioner. Whether the motion for reconsideration was filed within the reglementary period.
Ruling
The petition for certiorari is denied. The decision of the Court of Industrial Relations is affirmed.
Ratio Decidendi
On Whether the decision of the Court of Industrial Relations is null and void for being signed by only one member: The Court held that the contention is unfounded. Commonwealth Act No. 103, as amended by Commonwealth Act No. 559, provides that the judges shall act on matters designated by the Presiding Judge, and each judge has the authority to preside over assigned cases and render decisions therein. Therefore, a decision signed by a single member acting within his assigned jurisdiction is valid. On Whether the Court of Industrial Relations acquired jurisdiction over the person of the petitioner: The Court found that the petitioner had submitted herself to the jurisdiction of the Court of Industrial Relations. This was evidenced by her representative, Francisco Anchuelo, filing a memorandum on January 31, 1949, after the case was elevated to the CIR. By filing a memorandum, she had the opportunity to be heard, thereby conferring jurisdiction upon the court. On Whether the motion for reconsideration was filed within the reglementary period: The Court ruled that the motion for reconsideration was filed out of time. The petitioner received a copy of the decision on April 1, 1949, and filed her motion for reconsideration on April 8, 1949. This period of seven days exceeded the five-day reglementary period prescribed by Article 8 of the Rules of the Court of Industrial Relations, which allows a party five days from receipt of the notice of the decision to file a petition for reconsideration. The Court noted that the denial of the motion for reconsideration was dated May 26, 1948, which is prior to the decision date of March 22, 1949, and the receipt of the decision by the petitioner on April 1, 1949, indicating a potential clerical error in the date of denial but affirming the principle that the motion was filed late based on the stated receipt date and filing date. The Court concluded that the decision had become final due to manifest negligence ('desidia manifiesta').
Main Doctrine
The Court of Industrial Relations has the authority to promulgate its own rules of procedure. A party adversely affected by a decision must file a petition for reconsideration within five days from receipt of the notice of the decision. Failure to do so, due to manifest negligence, results in the decision becoming final and executory.