Elcee Farms, Inc. v. Semillano
REITERATIONFacts
1. The Antecedents: A complaint for illegal dismissal was filed by 144 employees against Elcee Farms, Inc., Corazon Saguemuller, and others. Initially, only 28 employees submitted evidence. The Labor Arbiter ordered Hilla Corporation to pay separation pay to these 28 complainants but dismissed claims against Elcee Farms and Saguemuller. The NLRC later modified this, holding Elcee Farms and Saguemuller liable for separation pay and moral damages, and increased the number of awardees to 131 based on SSS contributions. 2. Procedural History: Following the NLRC's modified decision, petitioners Elcee Farms and Saguemuller filed two separate petitions for certiorari with the Supreme Court. The first petition (G.R. No. 125714) was denied for failure to file within the granted extension. The second petition (G.R. No. 126428) was dismissed for non-compliance with a resolution requiring payment of costs and submission of memoranda, due to the resolution being sent to an incorrect address. Subsequently, petitioners filed a petition for annulment of judgment with the Court of Appeals, which was dismissed for lack of jurisdiction. This dismissal led to the present petition for review on certiorari before the Supreme Court. 3. The Petition: The petitioners seek review of the Court of Appeals' decision dismissing their petition for annulment of judgment. They argue that the Court of Appeals erred in refusing to assume jurisdiction and annul a decision they deem unjust. The petition raises issues concerning the NLRC's decision to award damages to individuals who did not pursue their claims, the consideration of evidence for the first time on appeal, and the alleged rendering of judgment against a party not properly involved. Additionally, they claim extrinsic fraud in the Supreme Court proceedings due to the misaddressed resolution that led to the dismissal of their second certiorari petition.
Issue(s)
Whether the Court of Appeals has jurisdiction to annul a final and executory decision of the NLRC. Whether the petitioners are guilty of forum shopping. Whether the dismissal of the petitioners' previous certiorari petitions before the Supreme Court should be considered as a disposition on the merits. Whether the petitioners should be bound by the negligence or mistake of their counsel regarding the procedural missteps in their certiorari petitions. Whether the service of the Supreme Court's resolution in G.R. No. 126428 was valid.
Ruling
The petition for review on certiorari is DENIED for lack of merit. The Court finds no error in the assailed decision of the Court of Appeals. The Court of Appeals correctly held that it has no jurisdiction to entertain a petition for annulment of a final and executory judgment of the NLRC.
Ratio Decidendi
On the jurisdiction of the Court of Appeals to annul NLRC judgments: The Court reiterated that Section 9 of BP 129, as amended, vests in the Court of Appeals exclusive jurisdiction over actions for annulment of judgments of Regional Trial Courts. This jurisdiction does not extend to judgments of quasi-judicial bodies like the NLRC. Therefore, the Court of Appeals correctly dismissed the petition for annulment of judgment for lack of jurisdiction. The proper remedy for challenging a final and executory decision of the NLRC, if ordinary remedies are no longer available, would be a petition for certiorari before the Supreme Court under Rule 65, provided the grounds for annulment are met and the petitioners were not negligent. The Court emphasized that annulment of judgment is an extraordinary remedy allowed only when ordinary remedies like new trial, appeal, or petition for relief are no longer available through no fault of the petitioners. In this case, the petitioners had the remedy of certiorari before the Supreme Court, which they availed of twice, but both petitions were dismissed due to their failure to comply with procedural requirements. Their attempt to seek annulment of judgment before the Court of Appeals was therefore misplaced, as they had already pursued the appropriate remedy before the Supreme Court. On forum shopping: The Court found that the petitioners' actions in filing two separate certiorari petitions before the Supreme Court and subsequently a petition for annulment of judgment before the Court of Appeals constituted forum shopping. This is defined as repetitively availing of several judicial remedies, simultaneously or successively, founded on the same transactions and raising substantially the same issues. Forum shopping is considered an act of malpractice that degrades the administration of justice and abuses court processes. On the effect of dismissal of certiorari petitions: The Court clarified that minute resolutions of the Supreme Court denying due course to petitions or dismissing cases summarily for failure to comply with formal or substantial requirements are considered dispositions on the merits. Thus, the dismissal of the petitioners' two certiorari petitions meant that the NLRC decision had become final and executory. The petitioners' assertion that the dismissal was not on the merits was contrary to established jurisprudence. This finality precluded further challenges through an annulment of judgment. On the negligence of counsel and the validity of service: While acknowledging that the general rule is that a client is bound by the negligence of counsel, the Court noted exceptions where strict adherence to the rule would result in a miscarriage of justice. The Court expressed serious apprehensions regarding the validity of the service of the Supreme Court's resolution in G.R. No. 126428, which was allegedly sent to an incorrect address. The Court stated that if the service was indeed invalid and deprived petitioners of due process, this could be a ground for a more appropriate remedy, but not for an annulment of judgment before the Court of Appeals. On the validity of service and other concerns: The Court also expressed concern over the NLRC's resolution increasing the number of awardees based solely on SSS contributions, when only 28 employees submitted evidence. However, these concerns could not be resolved in the present petition for review or in a petition for annulment of judgment before the Court of Appeals.
Main Doctrine
The Court of Appeals does not have jurisdiction to entertain a petition for annulment of a final and executory judgment of the National Labor Relations Commission (NLRC). Such jurisdiction is vested exclusively in the Supreme Court.