Medina Investigation & Security Corporation v. Court of Appeals
REITERATIONFacts
1. The Antecedents: Respondent Romeo Taburnal was hired as a security guard by petitioner corporation on September 8, 1996. His client, Abenson, Inc., requested his relief on September 5, 1997, citing violations of the Service Contract, including tardiness, substandard performance, and exceeding the maximum duty period. Following his replacement, Taburnal filed a complaint for illegal dismissal, seeking separation pay, payment for holidays and overtime, 13th-month pay, and a refund of his cash bond and taxes. 2. Procedural History: The Labor Arbiter ruled in favor of Taburnal on April 29, 1999, ordering his reinstatement with backwages and salary differentials. Petitioners appealed to the National Labor Relations Commission (NLRC), which dismissed the appeal for lack of jurisdiction. A motion for reconsideration was denied. Petitioners then filed a petition for certiorari with the Court of Appeals. The Court of Appeals dismissed this petition on June 2, 2000, finding it was filed beyond the 60-day reglementary period, and denied the subsequent motion for reconsideration on July 12, 2000. 3. The Petition: Petitioners seek review of the Court of Appeals' resolutions dismissing their petition for certiorari. They contend that their petition was filed within the 60-day reglementary period, arguing that the period should be counted from their receipt of the NLRC's denial of their motion for reconsideration on April 3, 2000, making their May 31, 2000 filing the 58th day. They also raise issues regarding the NLRC's alleged grave abuse of discretion in affirming the Labor Arbiter's decision and holding Ernesto Z. Medina jointly and severally liable without sufficient evidence. The petition is filed under Rule 65 of the Rules of Civil Procedure.
Issue(s)
Whether the petition for certiorari filed with the Court of Appeals was filed within the 60-day reglementary period. Whether the NLRC committed grave abuse of discretion amounting to lack or excess of jurisdiction in affirming the Labor Arbiter's decision awarding monetary claims not prayed for in the complaint; and whether Ernesto Z. Medina was correctly held jointly and severally liable with MISCOR without sufficient evidence.
Ruling
The Supreme Court SET ASIDE the Resolutions dated June 2, 2000, and July 12, 2000, of the Court of Appeals and REMANDED the case to the Court of Appeals for further proceedings. SO ORDERED.
Ratio Decidendi
On the issue of the reglementary period for filing a petition for certiorari: The Court reiterated its ruling in Systems Factors Corporation and Modesto Dean vs. NLRC, et al. and Unity Fishing Development Corp. and/or Antonio Dee vs. CA, et al. that the amendment under A.M. No. 00-2-03-SC, which provides that the sixty-day period to file a petition for certiorari is reckoned from the receipt of the resolution denying the motion for reconsideration, should be deemed applicable to pending cases. The Court explained that remedial statutes or statutes relating to remedies or modes of procedure, which do not create new or take away vested rights but only operate in furtherance of the remedy or confirmation of existing rights, are not considered retroactive laws. Such procedural laws are retroactive in the sense that they apply to actions pending and undetermined at the time of their passage, and this retroactive application does not violate any vested right. The Court emphasized that procedural laws are generally not subject to the general rule against retroactive operation of statutes because no vested right may attach to or arise from them. This interpretation aligns with Section 6, Rule 1 of the 1997 Rules of Civil Procedure, which mandates liberal construction to promote speedy and inexpensive disposition of actions and proceedings. Therefore, the Court found that the CA erred in dismissing the petition for certiorari solely on the ground of being filed beyond the reglementary period, as the amended rule should have been applied. On the issues of grave abuse of discretion and joint and several liability: The Court stated that these other issues raised by the petitioners should be addressed and resolved by the court below, implying that the CA should have proceeded to rule on the merits of the petition for certiorari instead of dismissing it on a procedural technicality.
Main Doctrine
The amendment to Section 4, Rule 65 of the 1997 Rules of Civil Procedure, which provides that the sixty-day period to file a petition for certiorari is reckoned from receipt of the resolution denying the motion for reconsideration, is applicable to pending cases as it is a procedural law.