Asuncion v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondent Prudencio Agbuya, employed as a designer by ABC Mirror Tower and Aluminum Supply (ABC), was retrenched due to serious business reversal. He filed a complaint against petitioner Zenaida Asuncion, allegedly the general manager of ABC, and ABC itself, for illegal dismissal, violation of P.D. No. 525, non-payment of wages, and violation of R.A. No. 6640. Procedural History: The Labor Arbiter rendered a decision ordering the respondents to reinstate the complainant with backwages and pay salary differential. Due to petitioner's failure to file an appeal within the reglementary period, the decision became final and executory. Respondent filed a motion for a writ of execution, which was granted. Petitioner filed a motion to quash the writ, claiming the levied properties were hers and she was not an owner of ABC. The Labor Arbiter dismissed the motion to quash and declared petitioner liable for one-half of the judgment award. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's order. Petitioner filed a petition for certiorari with the Supreme Court. The Petition: Petitioner sought the reversal of the NLRC's decision, arguing that the judgment was rendered without due process and that she was not properly summoned. She also contended that even if summoned, the decision lacked factual and legal foundation.
Issue(s)
Whether the petition for certiorari should be granted to annul the NLRC's decision affirming the Labor Arbiter's order. Whether the Labor Arbiter's decision became final and executory due to petitioner's failure to appeal within the reglementary period. Whether the judgment, once final and executory, can be altered or set aside through a petition for certiorari. Whether petitioner was denied due process of law.
Ruling
The petition is dismissed. The questioned order dated February 25, 1992, and the decision of the National Labor Relations Commission dated January 21, 1993, are affirmed.
Ratio Decidendi
On the availability of certiorari as a remedy: The Court clarified that if the petitioner regarded the decision as void for lack of legal basis, her proper remedy would have been to appeal the judgment to the NLRC. Having failed to avail herself of this remedy within the reglementary period, the decision stands and cannot be collaterally attacked through a petition for certiorari. Certiorari is not a substitute for a lost appeal; it is an extraordinary remedy for correcting errors of jurisdiction, not errors of judgment. On the finality of the Labor Arbiter's decision: The Court reiterated the well-settled principle that the perfection of an appeal within the statutory or reglementary period is mandatory and jurisdictional. Failure to do so renders the decision final and executory, divesting the appellate court of jurisdiction to alter the judgment. In this case, the petitioner received the decision on April 26, 1991, making the last day for appeal May 6, 1991. Her failure to appeal within the ten-day period meant the decision became final and executory, entitling the prevailing party to its execution as a matter of right. This principle is fundamental in ensuring stability and finality in judicial proceedings. On the effect of a final and executory judgment: The Court emphasized that once a decision attains finality, it becomes the law of the case, irrespective of any perceived errors or infirmities. A judgment rendered by a court of competent jurisdiction acting within its authority cannot be altered, even if it contains legal infirmities. Such errors cannot be corrected through a petition for certiorari, which is limited to reviewing errors of jurisdiction or grave abuse of discretion amounting to lack of jurisdiction. The principle of immutability of judgments is crucial for maintaining order and preventing endless litigation. On the claim of denial of due process: The Court found no merit in petitioner's assertion of denial of due process. The records indicated that petitioner was not only served with summons but also filed an answer in the form of a position paper, wherein her inclusion as a respondent was not disputed. Furthermore, some notices were even addressed to her with the company as the forwarding addressee. These facts sufficiently contradicted her claim of not being properly summoned, establishing that she had the opportunity to be heard and present her case.
Main Doctrine
Failure to perfect an appeal within the reglementary period renders the decision final and executory, depriving the appellate court of jurisdiction to alter the judgment. A judgment that has attained finality becomes the law of the case and cannot be corrected by certiorari even if erroneous.