AMA Computer College-Santiago City, Inc. v. Nacino
REITERATIONFacts
The Antecedents: Chelly P. Nacino, employed as Online Coordinator at AMA Computer College-Santiago City, Inc. (AMA), was found absent from his post on October 30, 2002. Despite providing an explanation for his absence due to illness and inadequate school facilities, AMA's Human Resources Division Supervisor deemed the explanation unsatisfactory and initiated further investigation. This led to a formal complaint against Nacino for false testimony and abandonment, resulting in his preventive suspension and subsequent dismissal from service on December 5, 2002. Procedural History: Aggrieved by his dismissal, Nacino filed a complaint for illegal suspension and termination before the National Conciliation and Mediation Board (NCMB). The parties subsequently agreed to submit the controversy to a Voluntary Arbitrator. A compromise agreement was reached, wherein Nacino agreed to release AMA from all claims in exchange for P7,719.81. However, before the payment was made, Nacino died. The Voluntary Arbitrator, noting AMA's failure to pay the settlement amount and Nacino's withdrawal from the compromise, proceeded to render a decision on April 15, 2003, ordering Nacino's reinstatement and payment of backwages. A writ of execution was issued, leading to the garnishment of AMA's bank deposits. The Petition: AMA Computer College-Santiago City, Inc. filed a Petition for Certiorari under Rule 65 of the Rules of Civil Procedure before the Court of Appeals (CA), assailing the Voluntary Arbitrator's decision and writ of execution. The CA dismissed the petition, holding that the proper remedy was an appeal under Rule 43, not certiorari under Rule 65, and that the petition was procedurally flawed. AMA's motion for reconsideration was denied. Subsequently, AMA filed a Petition for Review on Certiorari under Rule 45 with the Supreme Court, arguing that the CA erred in dismissing its certiorari petition, contending that decisions under the Labor Code are not appealable under Rule 43 but under Rule 65, and that the Voluntary Arbitrator acted with grave abuse of discretion.
Issue(s)
Whether the Court of Appeals erred in dismissing AMA's petition for certiorari under Rule 65. Whether the Voluntary Arbitrator's Decision is appealable under Rule 43 or Rule 65 of the Rules of Civil Procedure. Whether the Voluntary Arbitrator acted with grave abuse of discretion, considering the timeliness of the remedy.
Ruling
The petition is denied for lack of merit. The assailed Court of Appeals Resolutions dated June 23, 2003 and March 3, 2004 are affirmed.
Ratio Decidendi
On the propriety of filing a petition for certiorari under Rule 65 instead of an appeal under Rule 43: The Court reiterated the ruling in Centro Escolar University Faculty and Allied Workers Union-Independent v. Court of Appeals, which held that decisions of a voluntary arbitrator under the Labor Code are appealable to the Court of Appeals via Rule 43 of the Rules of Civil Procedure. This is because a voluntary arbitrator is considered a government instrumentality within the contemplation of Section 9 of Batas Pambansa Blg. (BP) 129, and their decisions are akin to those of the Regional Trial Court, thus falling under the appellate jurisdiction of the Court of Appeals. The inclusion of decisions of voluntary arbitrators in Rule 43 was based on prior Supreme Court pronouncements, specifically Luzon Development Bank v. Association of Luzon Development Bank Employees. Therefore, filing a petition for certiorari under Rule 65 was indeed a wrong mode of review. On exceptions to the general rule: While acknowledging instances where certiorari may be granted despite the availability of appeal, such as when public welfare dictates, the broader interest of justice requires, the writs issued are null and void, or the order amounts to an oppressive exercise of judicial authority, the Court found that none of these exceptions attended the case at bar. AMA failed to demonstrate any exceptional circumstances that would justify a deviation from the general rule requiring an appeal under Rule 43. On the timeliness of the remedy: The Court emphasized that rules of procedure exist for a noble purpose and should not be disregarded. Even if a petition for certiorari could be treated as a petition for review under Rule 45, it would still be dismissed for being filed beyond the 15-day reglementary period. AMA received the Voluntary Arbitrator's Decision on April 15, 2003, but filed its petition for certiorari only on June 16, 2003. Applying the same reglementary period to appeals from decisions of Voluntary Arbitrators under Rule 43, the Voluntary Arbitrator's Decision had already become final and executory. The Court stressed that procedural rules ensure the orderly and speedy administration of justice and are not to be ignored for the convenience of a party.
Main Doctrine
Decisions of a voluntary arbitrator under the Labor Code are appealable to the Court of Appeals via Rule 43 of the Rules of Civil Procedure, not via a special civil action for certiorari under Rule 65, unless exceptional circumstances warranting deviation from the general rule are present. Failure to file the proper appeal within the reglementary period renders the decision final and executory.