Fabula v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: The underlying dispute involved Reynaldo A. Fabula filing a complaint against R. Mechanical Dynamics. The specifics of the complaint are not detailed in this excerpt, but it was initially heard by a Labor Arbiter. 2. Procedural History: Labor Arbiter Cresencio J. Ramos dismissed petitioner Fabula's complaint on August 11, 1978. Petitioner received this decision on October 16, 1978. Fabula then filed an appeal memorandum with the National Labor Relations Commission (NLRC) on November 3, 1978. R. Mechanical Dynamics filed a motion to dismiss this appeal on November 23, 1978. On May 30, 1980, the NLRC issued a resolution dismissing Fabula's appeal for being filed out of the reglementary period. 3. The Petition: This case is an appeal by certiorari to review the NLRC's resolution of May 30, 1980. The sole issue presented is whether petitioner Fabula's appeal memorandum, filed on November 3, 1978, was timely. The Solicitor General's manifestation indicates that considering weekends and public holidays between October 16 and November 3, 1978, only ten working days had elapsed, thus arguing the appeal was seasonably filed and erroneously dismissed.
Issue(s)
Whether the petitioner's appeal memorandum filed on November 3, 1978, was seasonably filed with the National Labor Relations Commission, considering the period from October 16, 1978, and the intervening non-working days. Whether the National Labor Relations Commission erred in dismissing the petitioner's appeal for being filed out of the reglementary period.
Ruling
The resolution of the National Labor Relations Commission is set aside, and the appeal is reinstated. No costs.
Ratio Decidendi
On Whether the petitioner's appeal memorandum filed on November 3, 1978, was seasonably filed with the National Labor Relations Commission, considering the period from October 16, 1978, and the intervening non-working days: The Supreme Court held that the petitioner's appeal memorandum was seasonably filed. The Court noted that the decision of the Labor Arbiter was received by the petitioner on October 16, 1978. The appeal memorandum was filed on November 3, 1978. The period between these dates is eighteen (18) calendar days. However, the Court, in agreement with the Solicitor General's manifestation, meticulously accounted for the non-working days within this period. These included two Saturdays, two Sundays, and four public holidays: October 26 and 27, declared non-working days due to typhoon Kading, and October 31 and November 1, by virtue of a Presidential Proclamation for All Saints Day. Therefore, out of the eighteen calendar days, eight were non-working days. This left only ten (10) working days from October 16 to November 3, 1978. Consequently, the filing of the appeal memorandum on November 3, 1978, was well within the reglementary period prescribed by law. The Court emphasized that the computation of reglementary periods must exclude such non-working days to ensure fairness and adherence to procedural rules. On Whether the National Labor Relations Commission erred in dismissing the petitioner's appeal for being filed out of the reglementary period: The Supreme Court ruled that the National Labor Relations Commission (NLRC) erred in dismissing the petitioner's appeal. The error stemmed from the NLRC's failure to properly compute the reglementary period by excluding the non-working days that occurred between the receipt of the decision and the filing of the appeal. As established in the reasoning for the first issue, the appeal was, in fact, timely filed when considering the exclusion of weekends and holidays. The NLRC's resolution, which dismissed the appeal solely on the ground of being filed out of time, was therefore based on an incorrect calculation of the period. The Court found it unquestionable that the appeal was timely filed, making the dismissal erroneous. Accordingly, the resolution of the NLRC was set aside, and the appeal was ordered to be reinstated for further resolution on its merits.
Main Doctrine
The Supreme Court reiterated that the reglementary period for filing an appeal must be computed by excluding weekends, holidays, and officially declared non-working days. In this case, the Court found that the petitioner's appeal memorandum was seasonably filed because the computation of the period from October 16, 1978, to November 3, 1978, correctly excluded two Saturdays, two Sundays, and four public holidays (October 26-27 due to typhoon Kading, and October 31-November 1 for All Saints Day), resulting in only ten working days, which was within the reglementary period.