Torres v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: Private respondents, teachers at St. James Child Care Center, were dismissed after failing to submit their transcripts of records as required by the school, which led to the withholding of their salaries. The teachers claimed this was an illegal dismissal and sought backwages, ECOLA, and other monetary claims. The school proprietor, petitioner Jaime T. Torres, contended that the dismissal was for a valid cause due to the teachers' violation of school rules and regulations, specifically their unexcused absence and failure to notify the school. He also argued that the teachers had received their ECOLA and that the backwage period exceeded their employment contracts. 2. Procedural History: The private respondents filed a complaint for illegal dismissal, illegal deduction, underpayment, and non-payment of wages and allowances against the school and its proprietor before the Labor Arbiter. The Labor Arbiter ruled in favor of the private respondents, ordering reinstatement and backwages, while dismissing other claims. The petitioner and the school appealed to the National Labor Relations Commission (NLRC). The NLRC affirmed the Labor Arbiter's decision with modification, limiting backwages to one year. Subsequently, the NLRC approved the computation of monetary claims, including ECOLA, and lifted an injunction on execution. A motion for reconsideration by the petitioner was denied by the NLRC. 3. The Petition: The petitioner filed a petition for certiorari under Rule 65 of the Rules of Court with the Supreme Court, seeking to nullify the NLRC's resolutions. The petition raises issues regarding the legality of the dismissal, the entitlement to ECOLA, and the period covered by the backwage award. The petitioner argues that the dismissal was justified, ECOLA was already paid, and the backwage period was excessive. The Supreme Court noted that the petition was filed beyond the reasonable period for a certiorari petition and that the petitioner, through their motion for clarification, had implicitly admitted the findings of illegal dismissal and non-payment of ECOLA. The Court also stated it would not act as a trier of facts regarding the employment contract period.
Issue(s)
Whether the National Labor Relations Commission committed grave abuse of discretion in holding that the dismissal from employment of private respondents was illegal. Whether the National Labor Relations Commission committed grave abuse of discretion in holding that private respondents were not paid their ECOLA. Whether the National Labor Relations Commission committed grave abuse of discretion in holding that private respondents are entitled to the award of one (1) year backwages.
Ruling
The petition is DISMISSED. The resolutions of the National Labor Relations Commission dated October 30, 1987, September 1, 1989, and September 29, 1989, are AFFIRMED.
Ratio Decidendi
On the illegality of dismissal: The Court held that the remedy of certiorari was no longer available as the petition was filed beyond the reasonable period for filing such a petition. Even if the period were dispensed with, the petitioner and the school were deemed to have admitted the finding of illegal dismissal by filing an urgent ex-parte motion for clarification of the award computation, indicating their concern was solely with the monetary award, not the legality of the dismissal itself. The Court emphasized that failure to raise an issue on appeal to the NLRC results in the finality of the ruling on that matter, and the petitioner's appeal did not question the finding of illegal dismissal. On the non-payment of ECOLA: The Court found that the petitioner and the school were deemed to have admitted the finding that ECOLA was not granted. This is because the propriety of the award of ECOLA was not raised as an issue in the appeal before the NLRC. When issues are limited on appeal, the NLRC can only review those issues raised, and all other matters become final and unreviewable. The petitioner's argument that ECOLA was included in the payroll sheets was considered a question of fact, which the Supreme Court does not typically resolve in a certiorari proceeding. On the award of one year's backwages: The Court reiterated that the petitioner's contention regarding the period covered by the employment contracts and the alleged overpayment of backwages involved a question of fact, which is beyond the scope of a certiorari petition. Furthermore, the Court noted that the petitioner and the school, by filing a motion for clarification solely on the computation of the award, implicitly accepted the NLRC's decision regarding the entitlement to backwages. The NLRC's modification of the Labor Arbiter's decision to limit backwages to one year was within its authority to affirm with modification.
Main Doctrine
A petition for certiorari must be filed within a reasonable period of time. Failure to raise an issue on appeal before the National Labor Relations Commission (NLRC) results in the finality of the ruling on that matter. The NLRC has the authority to affirm with modification decisions of Labor Arbiters, including the computation of monetary awards.