Universal Robina Corporation v. Court of Appeals
REITERATIONFacts
The Antecedents: Respondents Carlos C. Ygaña, Liborio Villaflor, and Ronaldo Cardinales, employees of CFC Corporation (an affiliate of petitioner Universal Robina Corporation), retired at age 60 and received retirement benefits under the company's plan, calculated as one-half month's pay for every year of service. Following the enactment of Republic Act No. 7641, which liberalized private sector retirement benefits, the respondents filed a consolidated complaint seeking retroactive application of these enhanced benefits. Procedural History: The Labor Arbiter ruled in favor of the respondents on January 15, 1999, ordering Universal Robina Corporation to pay specific amounts to each respondent. Petitioners appealed to the National Labor Relations Commission (NLRC), which affirmed the Labor Arbiter's decision in a resolution dated September 30, 1999, received by petitioners on November 11, 1999. Petitioners filed a motion for reconsideration on November 15, 1999, which was denied by the NLRC in a resolution dated December 29, 1999, and received by petitioners on March 14, 2000. The Petition: Petitioners filed a Petition for Certiorari with the Court of Appeals (CA) on May 15, 2000, seeking to annul the CA's resolutions dated May 18, 2000, and August 21, 2000. The CA dismissed the petition, holding it was filed out of time, as it was filed 6 days beyond the 60-day period reckoned from the receipt of the NLRC's denial of their motion for reconsideration, according to the prevailing rules at the time. This petition for review on certiorari under Rule 45 of the Rules of Court seeks to set aside the CA's dismissal, arguing that the petition was timely filed based on a subsequent amendment to the rules which retroactively allowed the 60-day period to be counted from the notice of denial of a motion for reconsideration.
Issue(s)
Whether or not the Petition for Certiorari filed by the petitioners in CA G.R. SP No. 58695 is dismissible for being filed out of time.
Ruling
The Petition is granted and the assailed Resolutions are set aside. The case is remanded to the Court of Appeals for further proceedings.
Ratio Decidendi
On the timeliness of the Petition for Certiorari: The Court held that the petition was filed on time. The Court of Appeals dismissed the petition based on the prevailing rule at the time, which was the July 21, 1998 Resolution in Bar Matter No. 803, amending Section 4, Rule 65 of the Rules of Court. This rule stated that if a motion for reconsideration is denied, the aggrieved party may file the petition within the remaining period, but not less than five days, reckoned from notice of such denial. However, the Court emphasized that the Rule was subsequently amended by AM No. 00-2-03-SC, effective September 1, 2000, which explicitly states that in case a motion for reconsideration is timely filed, the sixty (60) day period shall be counted from notice of the denial of the said motion. This amendment, being procedural or remedial, operates retroactively. Applying this retroactive effect, the petitioners received the NLRC Resolution denying their Motion for Reconsideration on March 14, 2000. They filed their Petition for Certiorari on May 15, 2000. The 60th day from March 14, 2000, was May 13, a Saturday. Therefore, they had until the next working day, May 15, to file their petition. The Court reiterated its previous rulings that the sixty-day period shall be reckoned from the receipt of the resolution denying the motion for reconsideration, and this amendment is applicable even if the petition was filed before September 1, 2000, as rules regulating procedures apply to pending and undetermined actions.
Main Doctrine
The sixty-day period within which to file a petition for certiorari is reckoned from the receipt of the resolution denying the motion for reconsideration, applying the retroactive effect of procedural rules.