Lopez Dela Rosa Development Corp. v. Court of Appeals
REITERATIONFacts
The Antecedents: Respondent Ariel Chavez filed a complaint for illegal dismissal and various monetary claims against petitioners Lopez Dela Rosa Development Corporation and Gloria Dela Rosa Lopez, alleging he was employed as a building maintenance employee on June 1, 1993, and was paid PHP120.00 daily. He claimed he worked overtime daily without pay, was denied 13th-month pay, sick leave, holiday pay, night shift differentials, and days-off. He further alleged that on December 8, 1994, after requesting a cash advance and reminding Gloria Lopez about minimum wage adjustments, he was terminated without due notice and hearing, allegedly for stealing two refrigerators, and filed a complaint on December 9, 1994. Petitioners denied the claims, asserting Chavez was terminated on December 14, 1994, due to willful failure to report for work from December 8 to 14, 1994, citing a "no work, no pay" basis and an employment contract dated January 3, 1994, and also alleged Chavez had taken company property without consent. Procedural History: The Labor Arbiter found Chavez was illegally dismissed and ordered reinstatement with backwages, salary from December 1-8, 1994, 13th-month pay, and attorney's fees. Petitioners appealed to the National Labor Relations Commission (NLRC), which dismissed the appeal on November 29, 1999, for failure to perfect it within the statutory period, and an entry of judgment was issued on January 25, 2000. Petitioners filed a motion for reconsideration, which the NLRC denied on June 30, 2000, stating no motion for reconsideration was filed with the Docket and Records Section and the submitted motion lacked the official stamp. Petitioners filed a petition for certiorari with the Court of Appeals (CA), which initially dismissed but later reinstated it. The CA, in its decision dated February 12, 2001, dismissed the petition, holding that the NLRC resolution of November 29, 1999, had become final and executory due to the failure to file a motion for reconsideration. The CA denied petitioners' motion for reconsideration on May 31, 2001. The Petition: Petitioners filed a Petition for Review on Certiorari with the Supreme Court, assailing the CA's decision and resolution. They argued that the NLRC should have relaxed the rule on posting a bond and resolved their motion to reduce bond before dismissing the appeal. They also contended that technicality should not hinder justice and that the NLRC committed serious errors and grave abuse of discretion.
Issue(s)
Whether the NLRC resolution dated November 29, 1999, dismissing the petitioners' appeal had become final and executory. Whether the petitioners had seasonably filed a motion for reconsideration of the NLRC resolution. Whether the Court of Appeals erred in affirming the NLRC's dismissal of the appeal.
Ruling
The petition is DENIED. The resolution of the NLRC dated November 29, 1999, dismissing the appeal of petitioners became final and executory on January 13, 2000, as evidenced by an Entry of Judgment. The Court found that petitioners failed to file a motion for reconsideration of the NLRC resolution, rendering it final and executory.
Ratio Decidendi
On the finality of the NLRC resolution: The Supreme Court affirmed the Court of Appeals' finding that the NLRC resolution dated November 29, 1999, had become final and executory. This was evidenced by an Entry of Judgment issued by the NLRC's Deputy Executive Clerk. The Court emphasized that this fact was not rebutted by the petitioners. The Court reiterated the mandatory nature of filing a motion for reconsideration within the 10-day reglementary period to prevent a resolution from becoming final and executory. This rule is based on Article 223 of the Labor Code and Section 14, Rule VII of the NLRC's New Rules of Procedure. The purpose of this rule is to give the NLRC an opportunity to correct any errors it may have committed before the case is elevated to higher courts. On the seasonable filing of a motion for reconsideration: The Court found the petitioners' claim of filing a motion for reconsideration to be unsubstantiated. The NLRC itself, in its resolution dated June 30, 2000, stated that no motion for reconsideration had been filed with its Docket and Records Section. The motion petitioners presented as evidence lacked the official stamp of the Docket Section. The Court found it incredible that a filed motion would not have any acknowledgment of receipt. Furthermore, the Court noted that the private complainant never received a copy of the alleged motion for reconsideration. Failure to furnish the adverse party a copy is considered a requirement for a motion to be entertained and is tantamount to non-filing. Without proof of service to the adverse party, a motion is considered an empty formality. On the Court of Appeals' affirmation of the NLRC's dismissal: The Court held that the Court of Appeals correctly affirmed the NLRC's dismissal of the appeal. Since the NLRC resolution had become final and executory due to the failure to file a motion for reconsideration, the petitioners' subsequent petition for certiorari with the Court of Appeals was based on a non-existent error. The Court found no valid reason to deviate from the rule that a motion for reconsideration is a mandatory prerequisite for further recourse. The Court also noted that petitioners deliberately omitted the fact of the entry of judgment in their petitions before the Court of Appeals and the Supreme Court, which further demonstrated their failure to comply with procedural requirements.
Main Doctrine
The seasonable filing of a motion for reconsideration within the 10-day reglementary period following the receipt of an order, resolution, or decision of the NLRC is a mandatory and jurisdictional requirement to forestall the finality of such order, resolution, or decision. Failure to comply renders the resolution final and executory.