U-Sing Button and Buckle Industry v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Fortunato Naya was employed as a maintenance worker by U-Sing Button and Buckle Industry from June 1960 until his death on May 30, 1986. Following his demise, his widow, Cecilia Naya, filed a claim against the company and its proprietor, Sy Ban, for separation pay and incentive leave pay due to her deceased husband. The company attempted to offset this claim by alleging Fortunato Naya owed them P16,500.00 and that they had provided him with P4,247.00 during his confinement and an additional P3,500.00 to his family upon his death. Cecilia Naya denied these allegations, asserting her husband had no debts and that signatures on receipts presented by the company were forged, with hospital bills being significantly lower than claimed. Procedural History: The case was initially heard by Labor Arbiter Daisy Cauton-Barcelona, who, after noting discrepancies in signatures presented by the respondents, dismissed the claim for underpayment but ordered the company to pay separation benefits. The respondents appealed this decision to the National Labor Relations Commission (NLRC). However, the NLRC dismissed their appeal due to their failure to post the required appeal bond of P18,369.00, which was equivalent to the monetary award. A subsequent motion for reconsideration filed by the respondents was also denied by the NLRC. The Petition: The petitioners, U-Sing Button and Buckle Industry and Sy Ban, filed a special civil action for certiorari with the Supreme Court, seeking to reverse the NLRC's resolution. They raised three main arguments: (1) the NLRC lacked jurisdiction because the commissioners' appointments were not confirmed by the Commission on Appointments; (2) the failure to file a surety bond was not a valid ground for dismissing their appeal; and (3) the NLRC erred in not ruling in their favor against Cecilia Naya. The Court found no merit in these contentions, upholding the validity of the commissioners' appointments and the necessity of complying with the statutory requirements for perfecting an appeal, particularly the posting of an appeal bond.
Issue(s)
Whether the NLRC had jurisdiction over the case given the appointments of its commissioners. Whether the failure to file a surety bond is a valid ground for dismissing an appeal. Whether the NLRC erred in ordering the payment of separation benefits to the private respondent.
Ruling
The petition for certiorari is DISMISSED. The Resolution of the National Labor Relations Commission is affirmed.
Ratio Decidendi
On the jurisdiction of the NLRC: The Court held that the appointment of NLRC Commissioners does not require confirmation by the Commission on Appointments. Citing Calderoti vs. Carale, the Court stated that their appointments are valid under Republic Act 6715. Furthermore, the petitioners are estopped from questioning the NLRC's jurisdiction as they had already recognized it by filing an appeal and a motion for reconsideration before the Commission. This reiterates the principle that parties cannot invoke the jurisdiction of a court or quasi-judicial body and then later deny it when the outcome is unfavorable. On the failure to file a surety bond: The Court affirmed that the posting of a cash or surety bond in the amount equivalent to the monetary award is a mandatory requirement for the perfection of an employer's appeal to the NLRC, as provided by Article 223 of the Labor Code, as amended by R.A. No. 6715, and Section 7 of the NLRC's Interim Rules. An appeal is a statutory right that requires strict compliance with its requisites. The failure to post the bond is a fatal defect that warrants the dismissal of the appeal, as it ensures the recovery of the judgment award should the appeal be unsuccessful. This aligns with the established jurisprudence that procedural rules, especially those concerning appeals, must be followed diligently. On the award of separation benefits: The Court found no grave abuse of discretion on the part of the NLRC. The records showed that Fortunato Naya had worked for 26 years without derogatory record and was 55 years old at the time of his death. Pursuant to the Labor Code, he was entitled to termination pay due to illness, computed at one-half month's pay for every year of service. The Court reiterated the principle that all doubts in the interpretation of labor and social laws should be resolved in favor of the worker. The factual findings of the NLRC and the Labor Arbiter were not found to be wildly distorted or contradicted, thus they were not subject to review in a certiorari proceeding.
Main Doctrine
The failure to post the required appeal bond for a monetary award is a fatal defect that warrants the dismissal of an employer's appeal to the National Labor Relations Commission. The appointment of NLRC Commissioners does not require confirmation by the Commission on Appointments, and their acts are valid.