Manila Terminal Relief Assn. v. Manila Terminal Co.
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a decision rendered by the Court of Industrial Relations (CIR) in case No. 86, filed by the Manila Terminal Relief and Mutual Aid Association against the Manila Terminal Company, Inc. The specifics of the dispute that led to the CIR's decision are not detailed in this excerpt, but it pertains to labor relations or employment matters. 2. Procedural History: The CIR, presided over by Judge V. Jimenez Yanson, issued a decision on April 1, 1950, which petitioner received on April 3, 1950. Petitioner filed a motion for reconsideration on April 10, 1950. This motion was denied by the CIR sitting en banc on July 13, 1950, with notice of denial received by petitioner on September 19, 1950. 3. The Petition: Petitioner filed a petition for certiorari with the Supreme Court on September 25, 1950, seeking to review the CIR's decision. Respondent Manila Terminal Company, Inc. moved for summary dismissal, arguing the petition was filed three days beyond the ten-day reglementary period, asserting the period should be counted from the initial notice of the judge's decision. The Supreme Court, however, ruled that the ten-day period for appeal by certiorari should be counted from the date of notice of the resolution of the Court of Industrial Relations sitting en banc on a motion for reconsideration.
Issue(s)
Whether the reglementary period for filing a petition for certiorari should be counted from the notice of the original decision of a single judge or from the notice of the denial of the motion for reconsideration by the Court of Industrial Relations sitting in banc. Whether the petition for certiorari was filed within the reglementary period.
Ruling
The motion for summary dismissal is denied. The petition for certiorari was filed within the reglementary period.
Ratio Decidendi
On the reglementary period for filing a petition for certiorari: The ten-day period within which an appeal by certiorari may be taken from a decision of the Court of Industrial Relations should be counted from the date the aggrieved party receives notice of the decision or order of the Court of Industrial Relations sitting in banc, where a motion for reconsideration has been filed against a ruling or decision of any of its judges. This is because a motion for reconsideration against a ruling or decision by one judge is in effect an appeal to the Court of Industrial Relations in banc. Therefore, there can be no appealable decision of said court until it has acted as a body on the motion for reconsideration. The denial of a motion for reconsideration by the court in banc signifies its affirmation or adoption of the one-judge decision, making the resolution of the court in banc the appealable decision. This interpretation is necessary to harmonize the provisions of Commonwealth Act No. 103, as amended, particularly Section 1 and Section 14, especially after the amendments increasing the number of judges and allowing motions for reconsideration to be resolved by the court in banc. On whether the petition was filed within the reglementary period: The petitioner received notice of the denial of its motion for reconsideration on September 19, 1950. The petition for certiorari was filed on September 25, 1950. This falls within the ten-day reglementary period from the notice of the resolution of the Court of Industrial Relations sitting in banc. Therefore, the petition was filed on time, and the motion for summary dismissal by the respondent Manila Terminal Company, Inc. is denied.
Main Doctrine
The ten-day period for appeal by certiorari from a decision of the Court of Industrial Relations should be counted from the date the aggrieved party receives notice of the decision or order of the Court of Industrial Relations sitting in banc, where a motion for reconsideration has been filed against a ruling or decision of any of its judges.