National Power Corporation v. Degamo
REITERATIONFacts
The Antecedents: Roel R. Degamo was employed by the National Power Corporation (NPC) and appointed as senior plant mechanic, and later as Electrical Control Operator, co-terminus with a project. He requested a transfer to another plant, which was approved by his manager. However, upon reporting for the transfer, he was informed that his transfer was rejected due to the manning level being reached. When he attempted to return to his former position, he was told he had already been replaced and was effectively on "floating status." Subsequently, he received a letter directing him to report for work within 72 hours or be dropped from the rolls. He reported but was again told his former position was filled. NPC later informed him he was dropped from the rolls effective September 30, 1997, citing his failure to report for work and stating his transfer required Selection Board action, which he was allegedly informed of. Procedural History: Degamo filed a complaint with the Civil Service Commission (CSC), which ruled in his favor, setting aside the order dropping him from the rolls and directing his reinstatement. The CSC reversed this decision on appeal, finding the unnumbered office order for transfer invalid and ruling that Degamo's appointment was co-terminus with the project. The Court of Appeals (CA) reversed the CSC, reinstating Degamo. NPC filed a motion for reconsideration with the CA beyond the reglementary period, attaching a "Notice of Termination" based on Republic Act No. 9136 (EPIRA Law). The CA initially granted the motion but later set aside its resolution upon Degamo's motion, citing the belated filing and lack of merit. The CA also noted that the EPIRA Law issue was raised for the first time and thus could not be considered. The Petition: NPC filed a petition for review on certiorari with the Supreme Court, assailing the CA's decision for holding that Degamo's dropping from the rolls was unjustified, denying its motion for leave to admit its motion for reconsideration solely on technicality, not considering Degamo's co-terminus appointment status, and not considering the EPIRA Law.
Issue(s)
Whether or not the Court of Appeals erred and committed grave abuse of discretion in holding that respondent’s dropping from the rolls of NPC was not justified. Whether or not the Court of Appeals erred and committed grave abuse of discretion in denying the petitioner’s motion for leave to admit its motion for reconsideration after it has been granted admission solely on technicality. Whether or not the Court of Appeals erred and committed grave abuse of discretion in not considering the status of appointment of Mr. Degamo which is permanent co-terminus with the project and effective only until December 1997. Whether or not the Court of Appeals erred and committed grave abuse of discretion in not considering Republic Act No. 9136, otherwise known as the EPIRA Law, in resolving NPC’s motion for reconsideration of the case.
Ruling
The petition is denied for lack of merit. The decision of the Court of Appeals had become final and executory as of March 6, 2004. The motion to admit the motion for reconsideration was filed on March 10, 2004, beyond the reglementary period, divesting the CA of jurisdiction. The Court also noted that the main issues were factual, which it is generally proscribed from reviewing under Rule 45. Finally, the reinstatement is without prejudice to the provisions of R.A. No. 9136.
Ratio Decidendi
On Issue 1: The Supreme Court did not directly rule on the substantive issue of whether Degamo's dropping from the rolls was justified because the assailed decision of the Court of Appeals had already become final and executory as of March 6, 2004. The petitioner, National Power Corporation (NPC), only filed its motion to admit its motion for reconsideration on March 10, 2004, which was beyond the reglementary period. Consequently, by the time NPC sought to challenge the CA's decision, the CA had lost jurisdiction to review, reverse, or modify its own decision. This adherence to the finality of judgment is a fundamental principle of procedural law. On Issue 2: The Supreme Court affirmed the Court of Appeals' decision to set aside its earlier resolution that had granted NPC's motion for leave to admit its motion for reconsideration. The CA correctly held that the original decision had become final and executory on March 6, 2004, four days before NPC filed its motion on March 10, 2004. The Court reiterated that the failure to file a motion for reconsideration within the prescribed period is not a mere technicality; rather, it raises a jurisdictional problem that divests the appellate court of jurisdiction over the case. Citing Oro v. Diaz, the Court emphasized that a winning party has the correlative right to enjoy the finality of a case. NPC failed to present any exceptional or extraordinary circumstances that would warrant a relaxation of the rules, thereby justifying the CA’s ultimate denial. On Issue 3: The Supreme Court declined to review the issue regarding Degamo's co-terminus appointment, stating that this is a factual issue. Under Rule 45 of the Rules of Court, the Supreme Court is proscribed from taking cognizance of and resolving factual issues, as it is not a trier of facts. While there are exceptional cases where the Court may resolve factual issues, NPC failed to demonstrate that such exceptional circumstances were present in this case. The factual findings of the Court of Appeals are generally conclusive on the Supreme Court. On Issue 4: The Supreme Court upheld the Court of Appeals' ruling not to consider Republic Act No. 9136 (R.A. No. 9136), also known as the Electric Power Industry Reform Act of 2001 (EPIRA Law). The CA correctly pointed out that this issue was raised for the first time in NPC’s motion for reconsideration, which is impermissible as it offends basic rules of fair play, justice, and due process, citing People v. Chua. Furthermore, the Supreme Court clarified that the reinstatement of Degamo, as ordered by the CA, is without prejudice to the provisions of R.A. No. 9136, meaning NPC retains its right to terminate Degamo's employment under the said law, subject to whatever monetary benefits he is entitled to under existing laws and R.A. No. 9136. This ensures that the reinstatement order does not preclude the application of subsequent valid legislation.
Main Doctrine
A motion for reconsideration filed beyond the reglementary period, absent exceptional or extraordinary circumstances, renders the appellate court's decision final and executory, divesting the court of jurisdiction to entertain the belated motion. The winning party acquires vested rights in the finality of the judgment.