Purcon v. MRM Philippines, Inc.
REITERATIONFacts
The Antecedents: Petitioner Julio B. Purcon, Jr. filed a complaint for reimbursement of medical expenses, sickness allowance, and permanent disability benefits against respondents MRM Philippines, Inc. and Miguel L. Rivera/Maritime Resources Management. Purcon alleged that he was hired as a seaman and developed a hernia while on duty, leading to his repatriation. He was declared fit to resume work by the company physician, but was not rehired due to lack of vacancy. Later, he was diagnosed with epididymitis and upper respiratory tract infection. Respondents countered that his hernia was not work-related, he was declared fit to work, and the ailment was correctable by surgery. They also pointed to a signed Quitclaim and Release. Procedural History: The Labor Arbiter dismissed Purcon's complaint, finding him fit to resume work and not suffering from a disability. The NLRC Third Division affirmed this decision on appeal, and a subsequent motion for reconsideration was denied, leading to the resolution becoming final and executory. Purcon then filed a petition for certiorari with the Court of Appeals (CA), which was dismissed due to formal infirmities. His motion for reconsideration was also denied, and the CA resolution became final. Subsequently, Purcon filed a petition for review on certiorari with the Supreme Court under Rule 45, which was denied due to late filing, failure to pay docket fees, and defective verification. An Entry of Judgment was issued. The Petition: Petitioner Purcon filed the instant petition for relief from judgment under Rule 38 of the 1997 Rules of Civil Procedure, seeking to set aside the Supreme Court's July 16, 2007 Resolution denying his petition for review and the subsequent October 9, 2007 Entry of Judgment. He cited the negligence and inefficiency of his counsel as grounds for the late filing and defective pleadings. The grounds raised included alleged gross mistakes by the Labor Arbiter and NLRC in their decisions, findings not based on substantial evidence, and decisions contrary to law and jurisprudence. The core issue presented to the Supreme Court was whether a petition for relief from judgment is a valid remedy before the Supreme Court.
Issue(s)
Whether a petition for relief from judgment under Rule 38 of the Rules of Court is an available remedy in the Supreme Court. Whether the negligence and inefficiency of counsel constitute excusable negligence warranting relief.
Ruling
The petition is DISMISSED. A petition for relief from judgment under Rule 38 of the Rules of Court is not an available remedy in the Supreme Court.
Ratio Decidendi
On the availability of a petition for relief from judgment in the Supreme Court: The Court held that a petition for relief from judgment under Rule 38 is an equitable remedy allowed only in exceptional cases when there is no other available or adequate remedy, and it must be filed with the same court that rendered the judgment or order sought to be set aside. Rule 56 of the Rules of Civil Procedure enumerates the original cases cognizable by the Supreme Court, and a petition for relief from judgment is not included in this list. Therefore, it is not an available remedy in the Supreme Court. The phrase "any court" in Rule 38 refers only to Municipal/Metropolitan and Regional Trial Courts. The procedures in the Court of Appeals and the Supreme Court are governed by separate provisions, and neither the Rules of Court nor the Revised Internal Rules of the CA allows for a petition for relief under Rule 38. The Supreme Court entertains only questions of law, whereas a petition for relief raises questions of fact concerning fraud, accident, mistake, or excusable negligence. On the alleged negligence of counsel: Even if the Court were to delve into the merits, the petition would still be dismissed. The late filing of the petition for review did not amount to excusable negligence. Petitioner's lack of devotion in discharging his duty, without demonstrating fraud, accident, mistake, or excusable negligence, cannot be a basis for judicial relief. For a claim of counsel's gross negligence to prosper, nothing short of clear abandonment of the client's cause must be shown. The relief afforded by Rule 38 will not be granted to a party who seeks to be relieved from the effects of a judgment when the loss of the remedy at law was due to his own negligence or a mistaken mode of procedure; otherwise, the petition for relief would be tantamount to reviving the right of appeal that has already been lost.
Main Doctrine
A petition for relief from judgment under Rule 38 of the Rules of Court is not an available remedy in the Supreme Court, as it is not among the original cases cognizable by this Court under Rule 56, and the remedy must be filed with the same court that rendered the judgment or order sought to be set aside.