Department of Agrarian Reform Multi-Purpose Cooperative v. Diaz
REITERATIONFacts
The Antecedents: Carmencita Diaz, Emma Cabigting, and Nina T. Samaniego were employed by the Department of Agrarian Reform Multi-Purpose Cooperative (DARMPC) as Accounting Clerk, Loan Officer and Verifier, and Lending Supervisor, respectively. In October 2003, the Cooperative discovered missing duplicate original receipts related to members' cash payments of share capital contributions. While some employees confessed to misappropriating funds and destroying the receipts, Diaz, Cabigting, and Samaniego were accused of being part of a conspiracy. They were subsequently placed under preventive suspension and, upon its expiration, were informed of their termination from employment. Procedural History: Diaz, Cabigting, and Samaniego filed a complaint for illegal dismissal against DARMPC. The Labor Arbiter initially dismissed their complaint, ruling they were members, not employees, and that their dismissal was justified. The National Labor Relations Commission (NLRC) reversed this, finding them to be employees but upholding their dismissal based on just cause, while awarding nominal damages for lack of due process. Both parties appealed. The Court of Appeals (CA) granted the petition for certiorari filed by Diaz, Cabigting, and Samaniego, reversing the NLRC's decision and finding them illegally dismissed. The CA ordered their reinstatement with backwages and other benefits, or separation pay in lieu of reinstatement, and attorney's fees. DARMPC's motion for reconsideration was denied by the CA. The Petition: Pursuant to Rule 45 of the Rules of Court, DARMPC filed a Petition for Review on Certiorari, assailing the CA's decision and resolution. DARMPC's counsel claimed the petition was filed late due to a misplaced resolution during the holiday season and his secretary's resignation. DARMPC argued that the CA erred in finding no just cause for dismissal and that due process was not violated. They also sought a temporary restraining order or writ of preliminary injunction to prevent the execution of the CA's decision, claiming it would lead to the Cooperative's bankruptcy. The respondents, in their comment, argued that the petition was filed out of time, lacked material dates, and raised factual issues improper for a Rule 45 petition. They also presented evidence indicating the petition was filed significantly beyond the reglementary period.
Issue(s)
Whether the Petition for Review on Certiorari was filed within the reglementary period. Whether the negligence of counsel binds the client (the Cooperative). Whether a final and executory judgment can be modified or reversed.
Ruling
The Supreme Court DENIED the Petition for Review on Certiorari. The Court held that the petition was filed out of time, and the negligence of the Cooperative's counsel binds the Cooperative. Consequently, the Court of Appeals' decision had become final and executory and could no longer be modified or reversed.
Ratio Decidendi
On the issue of the timeliness of the Petition: The Court reiterated that the period for filing a petition for review on certiorari is fifteen (15) days from notice of the judgment or resolution appealed from, as provided in Rule 45, Section 2 of the Rules of Court. Failure to file within this period results in the loss of the right to appeal and deprives the appellate court of jurisdiction. The Cooperative filed its petition on April 5, 2013, but the records showed that it received the Court of Appeals' Resolution denying its motion for reconsideration on September 20, 2012. This lapse of over six months clearly exceeded the reglementary period. The Court found the Cooperative's counsel's excuses for the delay, such as misplacing the resolution and being busy with elections, to be unsubstantiated and not justifiable reasons for a liberal application of the rules. The Court emphasized that a liberal construction of rules requires justifiable reasons or at least a reasonable attempt at compliance, which was absent in this case. On the issue of the negligence of counsel: The Court affirmed the established principle that the negligence of counsel binds the client. The Cooperative cannot disclaim responsibility for the failure of its counsel to monitor the dates and file the petition within the prescribed period. The Court stressed that "equity aids the vigilant, not those who slumber on their rights." Despite the Cooperative's claim that the execution of the CA ruling would lead to bankruptcy, it failed to diligently monitor its appeal or ensure timely action. Therefore, the negligence of Atty. Tamaca was binding upon the DARMPC. On the issue of the finality of judgments: The Court held that once a decision attains finality, it becomes the law of the case and can no longer be altered, modified, or reversed, except for clerical errors, nunc pro tunc entries, or void judgments. The Cooperative conceded that the CA decision had become final and executory. It failed to present any exceptions to the doctrine of immutability of judgments. The Court emphasized that "all litigation must come to an end, however unjust the result of error may appear." Since the CA decision was final and executory, it could no longer be disturbed, and the Cooperative's prayer for a TRO or injunction to prevent its execution was denied.
Main Doctrine
A petition for review on certiorari filed beyond the reglementary period, without justifiable reasons or a reasonable attempt at compliance, must be denied, as the negligence of counsel binds the client, and a final and executory judgment can no longer be altered.