Systems Factors Corporation v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioner Systems Factors Corporation employed private respondents Ronaldo Lazaga and Luis Singson as electricians. The private respondents filed a complaint against the petitioners for illegal dismissal and non-payment of various monetary claims, including backwages, service incentive fees, premium pay, separation pay, and other allowances. The Labor Arbiter ruled in favor of the private respondents, ordering reinstatement and payment of backwages. The National Labor Relations Commission (NLRC) affirmed this decision on appeal. Procedural History: Following the NLRC's affirmation of the Labor Arbiter's decision, petitioners filed a motion for reconsideration, which was denied by the NLRC. Petitioners then filed a petition for certiorari with the Court of Appeals (CA). The CA dismissed the petition, initially citing procedural deficiencies, specifically that the petition was filed out of time and that required documents were not certified. Upon a motion for reconsideration, the CA acknowledged that only the assailed NLRC resolutions needed certification but still denied the motion, maintaining that the petition was filed beyond the reglementary period. The Petition: Petitioners seek to set aside the CA's resolutions dismissing their petition for certiorari. They argue that the CA erred in calculating the sixty-day period for filing a certiorari petition. Petitioners contend that under the newly effective A.M. No. 00-2-03-SC, which amended Section 4, Rule 65 of the 1997 Rules of Civil Procedure, the period should be reckoned from the receipt of the resolution denying the motion for reconsideration. They further argue that procedural laws should be liberally construed to promote substantial justice and that a motion for reconsideration is a mandatory prerequisite before filing a certiorari petition, thus logically extending the period. The petition invokes the principle that procedural laws are generally retroactive in application to pending cases.
Issue(s)
Whether the 60-day period to file a petition for certiorari under Rule 65 should be reckoned from receipt of the resolution denying the motion for reconsideration pursuant to A.M. No. 00-2-03-SC. Whether the amendment introduced by A.M. No. 00-2-03-SC may be applied retroactively to cases pending at the time of its effectivity.
Ruling
The petition is GRANTED. The assailed Resolutions dated February 15, 2000, and June 22, 2000, of the Court of Appeals are SET ASIDE, and the case is REMANDED to the Court of Appeals for further proceedings.
Ratio Decidendi
On Issue 1: The Supreme Court held that the 60-day period for filing a petition for certiorari is now counted from the notice of the denial of the motion for reconsideration. Under A.M. No. 00-2-03-SC, which amended Section 4 of Rule 65, the rule was changed to simplify the counting of the reglementary period. The Court noted that since a motion for reconsideration is generally a mandatory prerequisite before filing a petition for certiorari, it is logical and practical for the period to begin anew upon notice of the denial of such motion. Applying this to the present case, the petitioners received the denial of their motion for reconsideration on November 25, 1999. Counting sixty days from that date leads to January 24, 2000, which was the exact date the petition was filed with the Court of Appeals, thus making the filing timely. On Issue 2: The Court ruled that procedural laws are inherently retroactive in application to pending cases. Citing the case of Castro vs. Sagales, the Court explained that remedial statutes relate to the mode of procedure and do not create new rights or take away vested ones. As such, they do not fall under the general prohibition against the retroactive operation of laws. The Supreme Court emphasized that no person has a vested right in procedural rules, and their retroactive application does not violate constitutional rights. Furthermore, Section 6, Rule 1 of the 1997 Rules of Civil Procedure mandates a liberal construction of rules to secure the just, speedy, and inexpensive disposition of actions. Consequently, the amendment to Rule 65 must be applied to the petitioners' pending case to prevent the denial of substantial justice due to procedural technicalities.
Main Doctrine
Procedural laws are retroactive in application to pending and undetermined actions, and their liberal construction is mandated to promote the objective of securing a just, speedy, and inexpensive disposition of every action and proceeding, as there is generally no vested right that attaches to procedural laws.