Daikoku Electronics v. Raza
REITERATIONFacts
The Antecedents: Petitioner Daikoku Electronics Phils., Inc. (Daikoku) hired respondent Alberto J. Raza as a company driver in January 1999, later assigning him as the personal driver for its president, Mamuro Ono. On July 21, 2003, Raza took the company vehicle home without authorization. The following morning, when questioned by Ono, Raza initially lied about where he parked the car. After admitting his dishonesty and apologizing, Raza was recommended for a 12-day suspension without pay by the investigation committee, considering his admission and apology as mitigating factors. However, Daikoku's general affairs manager dismissed Raza effective August 14, 2003, citing "dishonesty" and "other work related performance offenses" as grounds. Procedural History: Raza filed a case for illegal dismissal, and the labor arbiter ruled in his favor on January 15, 2005, finding the dismissal unlawful and ordering reinstatement with backwages, minus the 12-day suspension. Daikoku appealed this decision to the National Labor Relations Commission (NLRC). While the appeal was pending, Raza filed a motion to cite Daikoku in contempt for alleged refusal to reinstate him. The NLRC initially dismissed Daikoku's appeal but later reinstated it upon motion for reconsideration, reversing the labor arbiter's decision and declaring Raza's dismissal valid. However, the NLRC ordered Daikoku to pay Raza backwages for failing to reinstate him pending appeal. Both parties sought reconsideration. The NLRC denied Raza's motion but implicitly denied Daikoku's by issuing a resolution that concluded the controversy. Daikoku then filed a petition for certiorari with the Court of Appeals (CA), assailing the NLRC resolutions. The CA dismissed Daikoku's petition, finding it premature and that the NLRC resolution had become final and executory due to Daikoku's belated motion for reconsideration. The Petition: Daikoku Electronics Phils., Inc. filed this petition for review under Rule 45 of the Rules of Court, seeking to set aside the September 26, 2007 Decision and the February 7, 2008 Resolution of the Court of Appeals. Daikoku argues that the CA gravely abused its discretion by stating that the NLRC decision had attained finality. The core issue revolves around the timeliness of Daikoku's motion for reconsideration of the NLRC's May 31, 2006 resolution. The NLRC rules require motions for reconsideration to be filed within ten (10) calendar days from receipt of the decision. Daikoku received the resolution on June 16, 2006, but did not file its motion until July 3, 2006, which was 17 days later, thus rendering the motion belatedly filed and the NLRC resolution final and executory as to Daikoku.
Issue(s)
Whether the Court of Appeals gravely abused its discretion amounting to lack or excess of jurisdiction when it stated that the decision of the NLRC against the respondent already attained its finality. Whether the upholding of the grant of backwages to the respondent is unjust, baseless, and inequitable.
Ruling
The petition is DENIED for lack of merit. The CA Decision dated September 26, 2007, and Resolution dated February 7, 2008, in CA-G.R. SP No. 96282 are AFFIRMED.
Ratio Decidendi
On the issue of the finality of the NLRC Resolution: The Supreme Court affirmed the CA's finding that Daikoku's motion for reconsideration of the NLRC's May 31, 2006 Resolution was filed out of time. Daikoku received the resolution on June 16, 2006, and filed its motion on July 3, 2006, which is 17 days later. Section 15, Rule VII of the NLRC 2005 Rules of Procedure clearly provides a reglementary period of ten (10) calendar days for filing such motions. Therefore, Daikoku's motion was filed beyond the prescribed period, rendering the May 31, 2006 NLRC Resolution final and executory as to Daikoku. The Court reiterated that the relaxation of procedural rules is not granted liberally and requires valid and compelling reasons, which Daikoku failed to provide. The bare invocation of the interest of substantial justice is insufficient to justify non-compliance with mandatory procedural rules. The Court emphasized that procedural rules are not to be disregarded simply because their non-observance may have resulted in prejudice to a party's substantial rights. On the issue of backwages: The Court did not pass upon the merits of the NLRC's May 31, 2006 Resolution regarding the validity of Alberto Raza's dismissal or the propriety of the money award. The petition before the Supreme Court was primarily focused on the procedural issue of the timeliness of Daikoku's motion for reconsideration and the CA's decision thereon. The Court noted that Alberto Raza's own appeal, docketed as CA-G.R. SP No. 100714, was still pending before the CA. This pending appeal would allow for a full adjudication of the substantive issues, including the validity of the dismissal and the consequent money award. Therefore, the Supreme Court refrained from making any dispositive action that would preempt the CA's disposition of Raza's appeal, as the issue of whether there was a valid ground for dismissal is factual in nature and best threshed out before the appellate court.
Main Doctrine
A motion for reconsideration filed beyond the reglementary period of ten (10) calendar days from receipt of the resolution, as provided by Section 15, Rule VII of the NLRC 2005 Rules of Procedure, is considered filed out of time and renders the resolution final and executory. The relaxation of procedural rules requires valid and compelling reasons, and the bare invocation of 'the interest of substantial justice' is insufficient without such justification.