Pangasinan Employee Laborers and Tenants Association v. Martinez
REITERATIONFacts
1. The Antecedents: Patricio Tuliao, an employee of Pangasinan Transportation Company, Inc. (PANTRANCO), was suspended for 30 days on August 11, 1953, for driving a bus without authorization within the company terminal. The labor union representing Tuliao filed a petition with the Court of Industrial Relations (CIR), arguing the suspension was unjustified as Tuliao was merely saving the bus and its cargo from the rain. The CIR, through Judge Modesto Castillo, agreed and ordered Tuliao's reinstatement with back wages. This decision was affirmed by the Supreme Court in a prior certiorari proceeding. 2. Procedural History: Following the Supreme Court's affirmation, the case returned to the CIR for the computation of back wages. Judge Arsenio I. Martinez presided over this phase. After a stipulation of facts, Judge Martinez issued an order on March 17, 1958, adjusting Tuliao's back wages. Key adjustments included commencing the award on August 13, 1953, deducting earnings from other employment (P2,498.42 from Golden Taxicab), and ruling that Tuliao was not entitled to wages during the strike period from October 24, 1953, to January 18, 1954. The petitioners, PELTA and Tuliao, subsequently filed a motion for reconsideration. 3. The Petition: The petitioners seek review of the CIR's order, primarily challenging the timeliness of their motion for reconsideration. The core issue is whether the motion for reconsideration, filed on March 31, 1958, was submitted within the fifteen-day period prescribed by the CIR Rules. Conflicting affidavits from a clerk-messenger and a building caretaker present differing accounts of the motion's submission and receipt. The Supreme Court, agreeing with the CIR's assessment, found the motion to be filed out of time, rendering the order of Judge Martinez final and precluding further consideration of the merits of the case.
Issue(s)
Whether the motion for reconsideration filed by the petitioner was filed within the reglementary period. Whether the order of Judge Arsenio I. Martinez has become final.
Ruling
The petition is dismissed. The Supreme Court agreed with the Court of Industrial Relations that the motion for reconsideration was filed out of time. Consequently, the order of Judge Arsenio I. Martinez has become final and executory.
Ratio Decidendi
On whether the motion for reconsideration was filed within the reglementary period: The Supreme Court found itself inclined to agree with the court below that the motion for reconsideration was filed out of time. The Rules of the Court of Industrial Relations provide that a motion for reconsideration should be filed within fifteen days. The petitioner's claim of timely filing was supported by an affidavit stating the motion was filed on March 31, 1958. However, an opposing affidavit from the caretaker of the CIR building stated that the motion was presented on April 2, 1958, and the receiving clerk refused to accept it. While the Court acknowledged the practice of receiving clerks accepting papers in the evening after office hours, it emphasized the duty of the receiving clerk to accept the motion and stamp the actual date and hour of receipt to avoid disputes. The Court noted that even if the motion was presented on March 31, 1958, the circumstances surrounding its attempted filing and acceptance raised doubts about its timely and proper submission. The failure to have the motion officially received and stamped by the clerk of court was critical. On whether the order of Judge Arsenio I. Martinez has become final: Since the Supreme Court determined that the motion for reconsideration was filed out of time, the order of Judge Arsenio I. Martinez has become final and executory. The Court of Industrial Relations did not act on the motion, implying it considered it untimely. As the motion for reconsideration was not filed within the prescribed period, it lost its efficacy, and the original order stood. Consequently, the Supreme Court could not entertain the petition assailing the order because it had already attained finality. The procedural defect of filing out of time precluded any substantive review of the merits of the order by the Supreme Court.
Main Doctrine
A motion for reconsideration must be filed within the reglementary period. If filed out of time, the order sought to be reconsidered becomes final and executory, and the appellate court cannot entertain a petition assailing it.