Sunshine Transportation, Inc. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Sunshine Transportation, Inc. (petitioner) hired Realucio R. Santos (private respondent) as a probationary bus driver on August 24, 1989, and subsequently appointed him as a regular "Bus Driver Class C" on March 16, 1990. On January 7, 1992, Santos received a memorandum dated January 4, 1992, requiring him to explain his failure to report for a trip on December 28, 1991. Santos claimed he applied for leave on January 2, 1992, with the Operations Manager, who allegedly tore the application, verbally terminated his services, and forced him out. Santos then mailed his leave application on the same date. Subsequently, Santos received a termination letter dated January 22, 1992, citing insubordination for failing to submit the required explanation and deeming such failure an admission of guilt. Santos continued reporting for work but was denied entry, leading him to believe he was suspended or dismissed. Procedural History: Santos filed a complaint with the Labor Arbiter for illegal suspension, illegal dismissal, illegal deduction of allowance, non-payment of salaries, overtime pay, holiday premiums, rest day and night shift premiums, allowances, and separation pay, praying for reinstatement with back wages and moral damages. Petitioner cited several prior violations by Santos, including failure to remit cash collections, refusal to carry a passenger, late remittance of collections, attempted illegal exaction, stealing dogs, sexually harassing passengers, personal use of company buses, and punching in another employee's time card. The Labor Arbiter dismissed the complaint, finding Santos was dismissed for cause with due process and not entitled to money claims. The National Labor Relations Commission (NLRC) modified the decision, upholding the dismissal but granting Santos' money claims amounting to P158,000.00, stating petitioner failed to refute the claim of underpayment. The Petition: Petitioner filed a special civil action for certiorari with the Supreme Court, alleging the NLRC committed grave abuse of discretion by not dismissing Santos' appeal for non-compliance with appeal requirements, by granting money claims without factual or legal basis, by ruling that the 1989 money claims had not prescribed, and by failing to consider Santos' waiver/quitclaim for overtime pay.
Issue(s)
Whether the NLRC committed grave abuse of discretion in rendering its decision by failing to consider the available administrative remedy of a Motion for Reconsideration. Whether the NLRC erred in not dismissing Santos' appeal for failure to comply with mandatory requirements. Whether the NLRC erred in modifying the Labor Arbiter's decision by granting money claims without factual or legal basis. Whether the NLRC erred in ruling that Santos' money claims for 1989 had not prescribed. Whether the NLRC erred in failing to consider the waiver/quitclaim executed by Santos.
Ruling
The Supreme Court dismissed the petition for certiorari for lack of merit. The Court held that the petitioner failed to show that it had no plain, speedy, and adequate remedy in the ordinary course of law. Specifically, the records did not show, nor did the petitioner claim, that a motion for reconsideration of the NLRC decision was filed before resorting to the special civil action for certiorari. The Court reiterated that a motion for reconsideration is a plain, speedy, and adequate remedy and must be filed before a certiorari petition may be availed of, in light of the doctrine of exhaustion of administrative remedies, absent any plausible reason for direct recourse.
Ratio Decidendi
On the issue of grave abuse of discretion and exhaustion of administrative remedies: The Court found that the petitioner failed to demonstrate the absence of a plain, speedy, and adequate remedy in the ordinary course of law. It is settled jurisprudence that while a petition for certiorari under Rule 65 is a mode by which labor cases may reach the Supreme Court, it must be shown that the NLRC acted without or in excess of jurisdiction, or with grave abuse of discretion, and that there is no appeal, nor any plain, speedy, and adequate remedy in the ordinary course of law. Section 14, Rule VII of the New Rules of Procedure of the NLRC explicitly allows an aggrieved party to file a motion for reconsideration of any order, resolution, or decision of the NLRC. This constitutes a plain, speedy, and adequate remedy. Therefore, in light of the doctrine of exhaustion of administrative remedies, a motion for reconsideration must first be filed before a special civil action for certiorari may be availed of. The records of the case did not show, and the petitioner did not claim, that it filed such a motion for reconsideration before filing the instant certiorari petition. Neither did the petitioner suggest any plausible reason for direct recourse to the Supreme Court against the NLRC decision. Consequently, the petition was dismissed on this procedural ground. No ratio provided in the original text. No ratio provided in the original text. No ratio provided in the original text. No ratio provided in the original text.
Main Doctrine
A motion for reconsideration must be filed before a special civil action for certiorari may be availed of, absent any plausible reason for direct recourse to the Supreme Court.