Naguit v. San Miguel Corporation
REITERATIONFacts
The Antecedents: Petitioner Cesar Naguit was employed by respondent San Miguel Corporation as a machine operator. On September 23, 2002, Naguit and a co-employee, Renato Regala, engaged in an altercation at the company's Canlubang Plant. Naguit claimed he confronted Regala for distributing libelous anti-union materials and that the confrontation escalated when he elbowed Regala, causing him to fall. Regala filed a complaint with the company's Human Resources Department. Procedural History: Following an administrative investigation where Naguit opted not to defend himself, San Miguel Corporation terminated his employment on February 7, 2003, for willful injury to another employee. Naguit filed a complaint for illegal dismissal, which was dismissed by the Labor Arbiter on January 4, 2005. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision on April 30, 2008, and denied Naguit's motion for reconsideration on October 31, 2008. Naguit then sought to file a petition for certiorari with the Court of Appeals (CA). The Petition: Naguit filed a motion for extension of time to file his petition for certiorari with the CA, citing the need for a new counsel to study the case records after his former counsel received the NLRC resolution late. The CA denied this motion on February 13, 2009, holding that the 60-day period for filing a certiorari petition is non-extendible under the amended rules. The CA subsequently considered the petition as filed out of time. Naguit's motion for reconsideration was denied by the CA on July 15, 2009. The present petition for review on certiorari under Rule 45 of the Rules of Court assails these CA resolutions, arguing that the CA gravely abused its discretion by not deciding the case on its merits and by failing to consider the substantial facts and applicable laws.
Issue(s)
Whether or not the Court of Appeals gravely abused its discretion when it failed to decide the case on the merits by denying the motion for extension to file a petition for certiorari. Whether or not the Court of Appeals failed to look into the substantial facts and applicable laws of the case regarding the alleged illegal dismissal, and whether the NLRC and LA's factual findings should be upheld. Whether or not the petitioner had been unlawfully dismissed and thus is entitled to reinstatement and full backwages and other benefits as well as damages and attorney's fees, considering the proportionality of the penalty of dismissal for fighting within company premises.
Ruling
The petition is denied. The Resolutions of the Court of Appeals, dated February 13, 2009 and July 15, 2009, are affirmed.
Ratio Decidendi
On the procedural issue of the CA's denial of the motion for extension: The Court affirmed the CA's ruling that the 60-day period to file a petition for certiorari is generally non-extendible. Citing Thenamaris Philippines, Inc. v. Court of Appeals, the Court reiterated that while exceptions exist under compelling circumstances and the court's sound discretion, mere workload of a new counsel or the resignation of a former lawyer are insufficient justifications to relax procedural rules. The Court emphasized that failure to file the petition within the reglementary period results in the NLRC decision becoming final and executory, thus depriving the CA of jurisdiction. The Court stressed that procedural rules are not to be ignored at will and that parties must comply with them, as they are essential for the orderly administration of justice. The petitioner's duty to monitor his case and assist his counsel was also highlighted. On the substantive issues of illegal dismissal and the merits of the case: The Court held that it could not delve into questions of fact in a petition for review on certiorari, as only questions of law may be raised. It found no exceptions to this rule present in the case. The Court further noted that the factual findings of the NLRC, when supported by substantial evidence and coinciding with those of the LA, are accorded respect and finality. Even if the case were decided on its merits, the Court found no reason to depart from the LA and NLRC's findings that petitioner was validly dismissed. Substantial evidence supported the conclusion that petitioner committed serious misconduct and willful disobedience of company rules by fighting within company premises. Petitioner failed to present proof to counter the evidence against him. On the proportionality of the penalty of dismissal: The Court found no error in the dismissal penalty, even considering petitioner's 15 years of service and no prior offenses. The Court reiterated the settled rule that fighting within company premises constitutes a valid ground for dismissal and is considered serious misconduct. The Court cautioned that long years of service should not be a shield for disloyalty and that the law warrants dismissal when the evidence is sufficient to warrant it, regardless of whether the employee is a first-time offender or a habitual delinquent. The petitioner's violation was found to be willful, and he showed no remorse, even exhibiting a seemingly arrogant attitude by remaining silent despite opportunities to explain.
Main Doctrine
The 60-day period to file a petition for certiorari under Rule 65 of the Rules of Court, as amended, is generally non-extendible. While exceptions exist for compelling reasons and in the exercise of sound discretion, mere workload of a new counsel or the resignation of a former counsel are insufficient grounds to justify the relaxation of procedural rules, especially when the failure to file on time results in the loss of jurisdiction.