National Waterworks and Sewerage Authority v. National Waterworks and Sewerage Authority Supervisors Association and Court of Industrial Relations
REITERATIONFacts
1. The Antecedents: The National Waterworks and Sewerage Authority (NWSA) is the subject of a dispute stemming from a decision by the Court of Industrial Relations (CIR) in Case No. 71-IPA. This decision granted three demands made by the NWSA Supervisors Association: a 35% general salary increase for supervisors over three years, a revised effective date for the promotional appointments of Messrs. Modesto Blando and Rodolfo Ayalde to September 1, 1966, and the allowance of commutable transportation allowances for NWSA lawyers under the same terms as other officials, effective September 1, 1966. 2. Procedural History: The NWSA filed a petition for review of the CIR's decision dated November 22, 1968. However, the NWSA's appeal was filed out of time. Consequently, the Supreme Court was compelled to treat the case as a special civil action for certiorari, specifically challenging the CIR's finding that the appeal was late and the decision had become final and executory. The core of the procedural issue revolves around the timeliness of the NWSA's motion for reconsideration, which is a prerequisite for appeal under CIR rules. 3. The Petition: The NWSA seeks relief from judgment, arguing that its failure to file a timely motion for reconsideration was due to excusable neglect. They contend that service of the CIR decision on November 22, 1968, was followed by a weekend, an official trip by the Government Corporate Counsel, and the illness of a stenographer-secretary who was tasked with delivering the decision to the assigned attorney. The NWSA's petition for review, filed as a special civil action for certiorari, asserts that these circumstances prevented the timely filing of a motion for reconsideration and subsequent appeal, and requests that the Court consider the merits of the original decision. The Supreme Court, however, found these explanations insufficient to constitute excusable neglect, deeming the CIR's judgment final and unappealable.
Issue(s)
Whether the decision of the Court of Industrial Relations has become final and executory. Whether the circumstances presented by the petitioner constitute excusable neglect that would warrant relief from judgment.
Ruling
The petition is dismissed, and the decision of the Court of Industrial Relations of November 22, 1968, in Case No. 71-IPA, is declared final and executory.
Ratio Decidendi
On the issue of finality of judgment: The Court reiterated that under the CIR Rules of Procedure, a motion for reconsideration must be filed within four (or five, depending on the version of the rules applicable at the time) days from notice of the decision, and this requirement is jurisdictional. Failure to comply is fatal. The Court cited jurisprudence establishing that a motion for reconsideration filed out of time, or with supporting arguments filed out of time, renders the decision final and unappealable. In this case, the petitioner received the decision on August 6 and filed its motion for reconsideration on August 12, which was within the five-day period as August 11 was a Sunday. However, the supporting arguments were submitted on August 27, fifteen days after the motion was filed, and five days beyond the ten-day period allowed for submission of arguments. This lateness in filing the supporting arguments rendered the motion for reconsideration dismissible, and consequently, the judgment final. On the issue of excusable neglect: The Court found that the circumstances presented by the petitioner did not constitute excusable neglect. The explanation involving the illness of the secretary and the absence of the Government Corporate Counsel was deemed a "hackneyed and habitual subterfuge." The Court emphasized that even for government corporations, strict adherence to procedural rules is required, and alleged negligence of clerks or secretaries in handling court processes is generally not considered excusable. The Court noted that the petitioner's office failed to take adequate measures to ensure prompt attention to court processes, even on non-working days or in the absence of key personnel. The Court found the petitioner's reliance on the court's generosity and its failure to inquire about the status of its motion for extension to be indicative of a lack of diligence. The Court cited Philippine Air Lines, Inc. v. Arca and In re P. J. Kiener Co. Ltd. to support its ruling that such excuses do not constitute excusable negligence.
Main Doctrine
Failure to file a motion for reconsideration within the reglementary period, without a showing of excusable neglect, renders the decision final and executory, precluding further review.