Silliman University v. Fontelo-Paalan
REITERATIONFacts
The Antecedents: Respondent Nanila Fontelo-Paalan was employed by petitioner Silliman University in 1962 and served until her retirement on May 31, 1997, at the age of 57. Her retirement was based on the university's retirement plan, which stipulated automatic retirement after 35 years of uninterrupted service. Upon retirement, she received P102,410.00 in retirement benefits and an additional P46,219.25. Nearly three years later, respondent filed a complaint for illegal dismissal, arguing that the 35-year service clause in the retirement plan violated her constitutional right to security of tenure and Republic Act No. 7641, which sets the compulsory retirement age at 65. Procedural History: The Labor Arbiter initially ruled in favor of the respondent, finding her dismissal illegal and ordering reinstatement with backwages. However, the National Labor Relations Commission (NLRC) reversed this decision, upholding the validity of the retirement plan. Subsequently, in a resolution dated December 18, 2003, the NLRC modified its earlier ruling, ordering the petitioner to pay the respondent an additional P64,680.00 in retirement benefits. The petitioner sought reconsideration of this modification, but the NLRC denied it. The respondent then appealed the NLRC's decision to the Court of Appeals, which affirmed the NLRC's findings on both the validity of the retirement and the petitioner's liability for additional benefits. The respondent's motion for reconsideration of the Court of Appeals' decision was denied. The Petition: Petitioner Silliman University filed a Petition for Review on Certiorari under Rule 45 of the Revised Rules of Court, seeking to overturn the Court of Appeals' decision affirming the NLRC's order for the petitioner to pay P64,680.00 in additional retirement benefits. The petitioner argued against this liability. However, the Supreme Court noted that the petitioner failed to file a timely Petition for Certiorari before the Court of Appeals after the NLRC denied its motion for reconsideration regarding the additional benefits. This procedural lapse meant the NLRC's resolution on the additional benefits had become final and executory, rendering the Supreme Court without jurisdiction to entertain the petitioner's current appeal on that specific issue. The Court also denied the respondent's subsequent request to reverse the findings on illegal dismissal, citing similar procedural grounds.
Issue(s)
Whether the petitioner is liable for the balance of retirement benefits as adjudged by the NLRC and affirmed by the Court of Appeals. Whether the respondent was illegally dismissed.
Ruling
The Supreme Court denied the Petition for Review on Certiorari. It affirmed the Decision of the Court of Appeals dated January 19, 2005, and its Resolution dated December 7, 2005, which upheld the validity of the respondent's retirement and the petitioner's liability for additional retirement benefits.
Ratio Decidendi
On the issue of liability for additional retirement benefits: The Court found that the NLRC Resolution dated April 19, 2004, which denied the petitioner's Motion for Reconsideration of the December 18, 2003 Resolution ordering the payment of additional retirement benefits, had become final and executory. The petitioner received a copy of this resolution on July 13, 2004, and had until September 13, 2004, to file a Petition for Certiorari before the Court of Appeals but failed to do so. Instead, it was the respondent who assailed the adverse decision. The Court emphasized that a party who does not appeal an adverse judgment cannot seek its modification or reversal. By failing to file a timely Petition for Certiorari, the petitioner is deemed to have acquiesced to the judgment, making it immutable and unalterable. The Court reiterated the principle that once a decision becomes final and executory, it is removed from the power of the court to alter or amend it, and the winning party has a correlative right to enjoy the finality of the decision. The Court also noted that the petitioner's objection to the award of additional benefits was raised only in an Opposition with Manifestation Ad Cautelam, which cannot substitute for a Petition for Certiorari. Consequently, the Court deemed itself without jurisdiction to take cognizance of the petition on this sole issue due to the procedural lapse. On the issue of illegal dismissal and the applicability of the Jaculbe case: The Court noted that the respondent, having lost her case in the appellate court regarding illegal dismissal, accepted the adverse judgment and did not question it. The petitioner, on the other hand, was unsatisfied with the ruling on additional retirement benefits. The Court distinguished the present case from Alpha C. Jaculbe v. Silliman University because, in Jaculbe, the party timely raised the adverse decision, whereas in the present case, the respondent did not appeal the Court of Appeals' decision finding no illegal dismissal. Furthermore, the issues in Jaculbe were different, focusing on the validity of the retirement plan and illegal separation, while the sole issue in the present petition was the liability for additional retirement benefits. The Court also pointed out that Jaculbe had not yet become final and executory at the time of the decision. Therefore, the Court denied the respondent's prayer to reverse the NLRC and Court of Appeals decisions regarding illegal dismissal, citing the same procedural defect of inaction and acquiescence, which rendered those findings final and executory.
Main Doctrine
A party who fails to timely file a Petition for Certiorari to assail an adverse resolution from the NLRC is deemed to have acquiesced to the judgment, rendering the same final and executory, and thus beyond the jurisdiction of higher courts to review on substantive grounds.