Aquilink Maritime Inc. v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: This case concerns a dispute between Aqualink Maritime Inc. and Worlder Shipping Ltd. (petitioners) and Andrei Borgonia (private respondent) before the National Labor Relations Commission (NLRC). The specific underlying dispute leading to the Labor Arbiter's decision is not detailed in this resolution, but it resulted in a decision by Labor Arbiter Dominador A. Almirante. 2. Procedural History: The petitioners appealed the Labor Arbiter's decision dated July 19, 1996. Their appeal was dismissed by the NLRC on October 15, 1996, for being filed thirteen days after receipt of the decision. A motion for reconsideration was denied on November 20, 1996, as the registry return receipt indicated receipt on July 30, 1996. A subsequent motion for reconsideration was denied on January 28, 1997, as it was considered a second motion for reconsideration. 3. The Petition: The petitioners filed a special civil action for certiorari under Rule 65 of the Rules of Court, assailing the NLRC's resolutions. They contend that the NLRC gravely abused its discretion by dismissing their appeal. Petitioners argue they received the Labor Arbiter's decision on July 31, 1996, not July 30, 1996, as evidenced by a Postmaster's certification. They assert that their appeal, filed on August 12, 1996, was timely because August 10, 1996, the tenth day from July 31, 1996, was a Saturday, making the next working day, August 12, 1996, the last day to file.
Issue(s)
Whether the National Labor Relations Commission gravely abused its discretion in dismissing the petitioners' appeal, considering the timeliness of the appeal.
Ruling
The petition is GRANTED. The challenged resolutions of the NLRC dated October 15, 1996, and November 20, 1996, are SET ASIDE. The NLRC is DIRECTED to resolve the appeal on the merits. The records are remanded to the Commission.
Ratio Decidendi
On the issue of grave abuse of discretion and timeliness of appeal: The Court found that the NLRC committed grave abuse of discretion. The Court gave credence to the certification issued by the Postmaster of the Central Post Office of Manila, which stated that the petitioners received the Labor Arbiter's decision on July 31, 1996. This certification remained unrebutted before the NLRC. The Court noted that the registry return receipt, which the NLRC relied upon, did not clearly show the date of receipt, as the figure after '3' on the 'Date' line was unclear and could be read as '0' or '1'. The doubt was resolved in favor of July 31, 1996, based on the Postmaster's certification. Therefore, the petitioners had ten calendar days from July 31, 1996, to file their appeal, which meant the deadline was August 10, 1996. According to Section 1, Rule VI of the NLRC New Rules of Procedure, if the last day falls on a Saturday, Sunday, or holiday, the appeal must be filed on the next working day. Since August 10, 1996, was a Saturday, the appeal filed on August 12, 1996, was filed within the reglementary period. Consequently, the dismissal of the appeal and the denial of the first motion for reconsideration by the NLRC were erroneous.
Main Doctrine
The National Labor Relations Commission committed grave abuse of discretion in dismissing an appeal for being filed out of time when the appeal was, in fact, filed within the reglementary period, considering the correct date of receipt of the Labor Arbiter's decision and the provisions of the NLRC New Rules of Procedure regarding appeals falling on a Saturday.