Filipinas (Pre-fabricated Bldg.) Systems "Filesystems," Inc. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Respondents Cresenciano Bebanco, et al. filed a complaint against petitioners Filipinas (Pre-fabricated Bldg.) Systems, Inc. and Felipe A. Cruz, Jr. for illegal dismissal and various monetary claims, including service incentive leave, 13th month pay, and night shift differential, before the National Labor Relations Commission (NLRC). The initial proceedings before Labor Arbiter Donato G. Quinto, Jr. were marked by petitioners' failure to submit their position paper and evidence, leading the Arbiter to rule in favor of the respondents based on the evidence presented. Procedural History: Petitioners appealed the Labor Arbiter's decision to the NLRC, submitting for the first time evidence that respondents were project employees whose dismissal was due to project discontinuation. However, respondents challenged the NLRC's jurisdiction due to the late filing of the appeal bond. Despite this, the NLRC assumed jurisdiction and remanded the case to the Labor Arbiter for further proceedings. Upon denial of their motion for reconsideration, respondents filed a Petition for Certiorari with the Court of Appeals. The appellate court ruled that the NLRC lacked jurisdiction due to the untimely appeal bond and reinstated the Labor Arbiter's decision. The Petition: Petitioners seek review of the Court of Appeals' decision through a petition for certiorari under Rule 45 of the Rules of Court. They argue that the Court of Appeals erred in finding that the NLRC did not acquire jurisdiction over their appeal due to the late filing of the appeal bond, and in annulling the NLRC's resolution to remand the case. Petitioners also question the appellate court's decision to give due course to the respondents' petition for certiorari. The Supreme Court, however, found that the appeal bond was filed seven days beyond the reglementary period, and that the petition itself was filed beyond the fifteen-day period prescribed for appeals by certiorari, thus affirming the Court of Appeals' decision.
Issue(s)
Whether or not the Court of Appeals erred and committed grave abuse of discretion in finding and ruling that the NLRC has not acquired jurisdiction on the appeal of the petitioners for submitting an appeal bond seven (7) days beyond the ten (10)-day reglementary period in perfecting an appeal. Whether or not the Court of Appeals erred and committed grave abuse of discretion in its ruling regarding the remand of the case to the Labor Arbiter due to conflicting claims and the late submission of evidence. Whether or not the Court of Appeals erred and committed grave abuse of discretion in giving due course to the private respondents’ petition for certiorari and in annulling and setting aside the Resolutions of the NLRC, thereby reinstating the Decision of the Labor Arbiter, considering the timeliness of the petition before the Supreme Court.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals. The petition was dismissed, and the decision of the Labor Arbiter was reinstated with the modification that if reinstatement of respondents is not feasible, they should be paid separation pay in accordance with law.
Ratio Decidendi
On the jurisdiction of the NLRC over the appeal: The Court reiterated that Article 223 of the Labor Code and Section 1, Rule VI of the NLRC Rules of Procedure mandate that an appeal to the NLRC must be filed within ten (10) calendar days from receipt of the decision, award, or order. Crucially, in cases involving a monetary award, the appeal by the employer is perfected only upon the posting of a cash or surety bond equivalent to the monetary award. The Court emphasized that payment of the appeal bond is a jurisdictional requisite. In this case, the petitioners received the Arbiter's decision on October 31, 1998, and their appeal bond was executed on November 17, 1998, seven days beyond the reglementary period. There was no showing of partial payment during the reglementary period nor any explanation for the delay. Consequently, the late filing of the bond divested the NLRC of its jurisdiction to entertain the appeal. On the late submission of evidence and remand of the case: The Court found that petitioners should have adduced their evidence regarding the issue of illegal dismissal before the Labor Arbiter, as they were given opportunities to do so. The practice of submitting evidence only after an adverse decision is rendered before the NLRC cannot be tolerated as it defeats the speedy administration of justice and smacks of unfairness. The NLRC's act of remanding the case for further proceedings based on this late submission was therefore improper. On the timeliness of the petition before the Supreme Court: The Court also agreed with the respondents that the petition before it should not have been allowed as the decision of the Court of Appeals had already become final and executory. Petitioners received the denial of their motion for reconsideration from the Court of Appeals on November 9, 2001. Under Section 2, Rule 45 of the Rules of Court, a petition for review on certiorari must be filed within fifteen (15) days from notice of the judgment or final order or resolution appealed from. Petitioners obtained new counsel on November 23, 2001, but filed their extension request on June 16, 2002, well beyond the reglementary period. The Court held that the procedural lapse of the counsel in failing to file the appeal seasonably is binding on the petitioners.
Main Doctrine
The filing of an appeal bond within the reglementary period is a jurisdictional requisite for the perfection of an appeal to the National Labor Relations Commission (NLRC) in cases involving monetary awards. Failure to comply with this requirement, absent any showing of substantial compliance or compelling reason to relax the rule, divests the NLRC of jurisdiction to entertain the appeal. Similarly, the timely filing of a petition for review on certiorari with the Supreme Court is mandatory, and procedural lapses in this regard are binding on the petitioners.