Cristobal v. Philippine Airlines
REITERATIONFacts
The Antecedents: Petitioner Angelito L. Cristobal (Cristobal), a pilot for respondent Philippine Airlines, Inc. (PAL), applied for a leave without pay to work for EVA Air. PAL approved this, stating he would continue to accrue seniority and could opt to retire. Cristobal informed PAL of his intent to retire, but PAL deemed him to have lost his employment status. Cristobal filed a complaint with the National Labor Relations Commission (NLRC). Procedural History: The Labor Arbiter found Cristobal's dismissal illegal and ordered PAL to pay retirement pay, moral damages, exemplary damages, and attorney's fees. The NLRC affirmed the Labor Arbiter's decision but reduced the moral and exemplary damages. Cristobal filed a Motion for Partial Reconsideration, and PAL also filed a motion for reconsideration. In a subsequent Decision, the NLRC deleted the award for moral and exemplary damages and reduced Cristobal's retirement benefits, ruling that Article 287 of the Labor Code did not apply and that he was entitled to ₱5,000.00 per year of service under the 1967 PAL-ALPAP Retirement Plan. Cristobal filed another Motion for Reconsideration, arguing that the PAL Pilots Retirement Benefit Plan was distinct from the PAL-ALPAP Retirement Plan and was an investment plan. The NLRC denied this motion, treating it as a prohibited second motion for reconsideration. Cristobal then filed a Petition for Certiorari with the Court of Appeals, which dismissed his petition for being filed out of time, upholding the NLRC's view that Cristobal's June 24, 2011 motion was a prohibited second motion for reconsideration. The Petition: Cristobal filed a Petition for Review on Certiorari before the Supreme Court, assailing the Court of Appeals Resolutions that dismissed his Petition for Certiorari. He argued that his June 24, 2011 Motion for Reconsideration was not a prohibited second motion because it addressed the substantial reversal of his retirement benefits, and that the Court of Appeals erred in dismissing his petition for being filed out of time and for allegedly failing to attach pertinent documents.
Issue(s)
Whether the June 24, 2011 Motion for Reconsideration filed by petitioner Angelito L. Cristobal assailing the National Labor Relations Commission May 31, 2011 Decision was a prohibited second motion for reconsideration. Whether the Court of Appeals committed reversible error in dismissing the petition for certiorari outright for being filed out of time and for failure to attach requisite documents.
Ruling
The Supreme Court granted the petition, reversed and set aside the assailed Resolutions of the Court of Appeals, and directed the Court of Appeals to reinstate the petition for certiorari for further proceedings.
Ratio Decidendi
On the issue of the prohibited second motion for reconsideration: The Supreme Court held that the National Labor Relations Commission (NLRC) Rules of Procedure prohibit a party from questioning a decision, resolution, or order twice. However, a decision that substantially reverses a determination in a prior decision is considered a discrete decision from the earlier one. In this case, the NLRC's May 31, 2011 Decision substantially modified its September 30, 2010 Decision by deleting the award of moral and exemplary damages and reducing Cristobal's retirement benefits. Therefore, Cristobal was not precluded from seeking reconsideration of this new decision. The Court cited Poliand Industrial Ltd. v. National Development Co., Solidbank Corp. v. Court of Appeals, and Barba v. Licea De Cagayan University to support the principle that a motion for reconsideration of an amended or substantially modified decision is not a prohibited second motion. The Court emphasized that the prohibition contemplates the same party assailing the same judgment, and an amended decision that substantially reverses the original ruling creates a new basis for reconsideration. Thus, it was an error for the Court of Appeals to find that Cristobal's petition for certiorari was filed out of time on this ground. On the issue of the Court of Appeals' dismissal for failure to attach documents: The Supreme Court reiterated that procedural rules should not be used to frustrate the ends of justice. Citing Wack Wack Golf & Country Club v. National Labor Relations Commission and Novelty Philippines, Inc. v. Court of Appeals, the Court held that the subsequent submission of requisite documents can constitute substantial compliance. The Court noted that the main issue in Cristobal's petition was the alleged grave abuse of discretion by the NLRC in treating his motion as a prohibited second motion. Given that the records were already before the Supreme Court, it deemed it necessary to resolve the case to ensure harmony in rulings and expediency, rather than remanding it to the Court of Appeals for proper disposition on the merits. The Court found it reversible error for the Court of Appeals to have dismissed the petition for certiorari outright.
Main Doctrine
A motion for reconsideration seeking to address a substantial reversal of a prior decision by a tribunal is not a prohibited second motion for reconsideration, and its filing tolls the period to file a petition for certiorari.