Matagumpay Maritime Co. v. Dela Cruz
REITERATIONFacts
1. The Antecedents: Respondent Benedict C. Dela Cruz was employed by petitioner Matagumpay Maritime Co., Inc. as a seaman on May 10, 1993. Within two months, he was diagnosed with arthritis and later rheumatic heart disease, leading to his repatriation and medical treatment. Despite a physician declaring him fit to work on October 15, 1993, and attending a radar observation course, he was informed by a company representative in January 1994 that the company refused to re-employ him due to his ailment. His physician later confirmed his conditions as work-oriented arthritis and rheumatic heart disease in June 1994. 2. Procedural History: Respondent filed a complaint for illegal dismissal and non-payment of wages and disability benefits against the petitioners with the Labor Arbiter on October 24, 1997. The Labor Arbiter dismissed the complaint but awarded financial assistance. Upon appeal, the National Labor Relations Commission (NLRC) modified the decision, affirming the dismissal but granting disability benefits. Petitioners' motion for reconsideration was denied by the NLRC. Subsequently, petitioners filed a petition for certiorari with the Court of Appeals, which dismissed the petition as being filed late. 3. The Petition: Petitioners seek review of the Court of Appeals' dismissal of their petition for certiorari. They contend that the Court of Appeals erred in ruling that their petition was filed late. The Court of Appeals found that the petition was filed ten days beyond the allowable period after the denial of their motion for reconsideration by the NLRC. Petitioners argue that they should have been granted an extension or that the calculation of the period was incorrect. The respondent asserts that the Court of Appeals correctly applied the rules regarding the timeliness of filing a petition for certiorari.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari for being filed out of time. Whether the NLRC's resolution awarding disability benefits had become final and executory.
Ruling
The petition is denied. The challenged Resolutions of the Court of Appeals are affirmed.
Ratio Decidendi
On the timeliness of the petition for certiorari: The Court reiterated that Section 4, Rule 65 of the 1997 Rules of Civil Procedure mandates that a petition for certiorari must be filed not later than sixty (60) days from notice of the judgment, order, or resolution sought to be assailed. This period is interrupted by the filing of a motion for new trial or reconsideration in due time. If the motion is denied, the aggrieved party may file the petition within the remaining period, but not less than five (5) days. In this case, petitioners received the NLRC Resolution on December 7, 1999, and filed a motion for reconsideration on December 17, 1999. The NLRC denied the motion on April 20, 2000, and petitioners received it on May 11, 2000. From May 11, 2000, petitioners had fifty (50) days remaining to file their petition for certiorari. However, they filed it only on July 10, 2000, which was sixty (60) days after May 11, 2000. Thus, the petition was filed ten (10) days late. The Court emphasized that certiorari is an extraordinary remedy and requires strict observance of legal rules, particularly the reglementary period. As the assailed NLRC Resolutions had become final and executory due to the late filing of the petition for certiorari, the Court of Appeals could no longer review them for grave abuse of discretion. Therefore, the appellate court did not err in dismissing the petition before it for being late. On the finality of the NLRC's resolution: As the assailed NLRC Resolutions had become final and executory due to the late filing of the petition for certiorari, the Court of Appeals could no longer review them for grave abuse of discretion.
Main Doctrine
A petition for certiorari must be filed within the reglementary period prescribed by law. Failure to file within the 60-day period, even after filing a motion for reconsideration, renders the petition time-barred, precluding review by the appellate court.