Ciacico v. National Labor Relations Commission
REITERATIONFacts
The Antecedents This case originated from a labor dispute involving Noel F. Ciacico and Toyota Motors Philippines Corporation. The specific nature of the underlying labor dispute is not detailed in the provided text, but it led to a decision by the National Labor Relations Commission (NLRC). Procedural History Petitioner Noel F. Ciacico received the NLRC Decision on September 14, 1998. He subsequently filed a Motion for Reconsideration on September 24, 1998. The NLRC denied this motion, and petitioner received notice of this denial on December 4, 1998. The Supreme Court initially dismissed Ciacico's petition for certiorari on March 3, 1999, citing late filing of the petition and late payment of docket fees. The Petition Petitioner filed a Motion for Reconsideration of the Supreme Court's dismissal, arguing that his petition for certiorari was filed within the prescriptive period. He contended that he received the NLRC Decision on September 14, 1998, and filed his petition on January 28, 1999, which he believed fell within the sixty-day period allowed. However, the Court found that after receiving the denial of his motion for reconsideration on December 4, 1998, he had fifty-one days remaining to file his petition, and his filing on January 28, 1999, was fifty-five days after the denial, thus exceeding the prescribed period.
Issue(s)
Whether the petition for certiorari was filed within the reglementary period. Whether the filing of a motion for reconsideration with the NLRC interrupted the prescriptive period for filing a petition for certiorari with the Supreme Court.
Ruling
The motion for reconsideration is denied with finality. The petition for certiorari was filed beyond the reglementary period.
Ratio Decidendi
On whether the petition for certiorari was filed within the reglementary period: The Court reiterated that under Sec. 4 of Rule 65, as amended by Circular No. 39-98, a petition for certiorari must be filed not later than sixty (60) days from notice of the judgment, order, or resolution sought to be assailed. This period is interrupted if a motion for new trial or reconsideration is filed in due time. If the motion is denied, the aggrieved party may file the petition within the remaining period, but not less than five (5) days, reckoned from notice of such denial. No extension of time shall be granted except for the most compelling reason and in no case to exceed fifteen (15) days. On the interruption of the prescriptive period: Applying the rules on computation of time under Rule 22, the Court found that when petitioner received the NLRC decision on September 14, 1998, and filed his motion for reconsideration on September 24, 1998, nine (9) days of the sixty (60) day prescriptive period were consumed. Upon receiving the Resolution denying his motion for reconsideration on December 4, 1998, petitioner had fifty-one (51) days remaining within which to file his petition. However, he filed the petition on January 28, 1999, which was fifty-five (55) days after December 4, 1998. This period is beyond the fifty-one (51) days remaining and thus, the petition was filed late.
Main Doctrine
The filing of a motion for reconsideration interrupts the prescriptive period for filing a petition for certiorari. If the motion is denied, the aggrieved party has the remaining period, but not less than five (5) days, to file the petition, reckoned from notice of the denial. No extension shall be granted except for the most compelling reason and not exceeding fifteen (15) days.