Elizalde & Co. v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: Petitioner Elizalde & Co., Inc. was declared by the Court of Industrial Relations (CIR) to have respondent Apolinar Perlado as its employee, entitled to overtime pay and additional compensation for work on Sundays and legal holidays. Procedural History: Petitioner received the CIR decision on August 6, 1963. It filed a motion for reconsideration on August 12, 1963, without arguments. On August 21, 1963, it moved for an extension to file arguments. The arguments were filed on August 27, 1963. On September 16, 1963, the CIR en banc dismissed the motion for reconsideration because the arguments were filed out of time. Petitioner filed its notice of appeal and petition for certiorari on October 3, 1963. The Petition: Petitioner challenges the CIR's decision and resolution, arguing that the judgment had not become final.
Issue(s)
Whether the CIR judgment declaring respondent Apolinar Perlado as petitioner's employee and entitled to overtime pay and additional compensation had become final and unappealable. Whether the CIR erred in dismissing petitioner's motion for reconsideration on the ground that the supporting arguments were filed out of time.
Ruling
The petition is denied. The CIR judgment has become final and unappealable.
Ratio Decidendi
On the finality of the CIR judgment: The Court held that the judgment of the CIR had become final and unappealable. The rules of procedure of the CIR, as amended, and the jurisprudence of the Supreme Court mandate that a motion for reconsideration must be filed within five days from receipt of notice of the decision. Furthermore, the arguments in support of such motion must be filed within ten days from the filing of the motion for reconsideration. Failure to observe these periods is sufficient cause for dismissal of the motion. In this case, the arguments were filed fifteen days after the motion for reconsideration was filed, which was five days beyond the reglementary period. The Court emphasized that public policy and sound practice demand that judgments become final at a definite date to put an end to controversies. The CIR's standing rule against extensions for filing supporting arguments should have alerted the petitioner to the strictness of the deadline. The motion for extension filed by petitioner was not acted upon favorably, and the subsequent filing of arguments beyond the expired period did not cure the defect. Therefore, the CIR's dismissal of the motion for reconsideration was proper, rendering the judgment final and unappealable. On the dismissal of the motion for reconsideration: The Court affirmed the CIR's resolution dismissing the motion for reconsideration. The dismissal was based on the ground that the supporting arguments were filed out of time, which is a valid ground under the CIR Rules of Procedure. The Court cited several of its own rulings, such as Bien vs. Castillo, Pangasinan Employees, Laborers & Tenants Association (PELTA) vs. Martinez, Local 7, Press & Printing Free Workers (FFW) vs. Tabigne, and Luzon Stevedoring Co., Inc. vs. Court of Industrial Relations, which consistently uphold the finality of judgments when procedural rules regarding the filing of motions and supporting arguments are not strictly followed. The petitioner's failure to file its arguments within the ten-day period, and its neglect in not inquiring about the status of its motion for extension before the deadline passed, led to the expiration of the reglementary period. Consequently, the CIR correctly dismissed the motion, and the judgment became final and unappealable.
Main Doctrine
A judgment becomes final and unappealable if the arguments in support of a motion for reconsideration are filed out of time, and the Court of Industrial Relations has a standing rule against the extension of the period for filing such arguments.