Fajardo v. San Miguel Foods
REITERATIONFacts
1. The Antecedents: Petitioners, formerly employed as laborers by Bataan Mariveles Port Services Corporation and later absorbed by Hua Tong Far East Inc. (Hua Tong), worked at San Miguel Foods, Inc. (SMFI) B-MEG Plant 1 from 2005 to 2006. Their employment was terminated on December 31, 2019, following SMFI's decision not to renew its business relationship with Hua Tong. Petitioners subsequently filed a case for illegal dismissal against SMFI and Hua Tong, alleging that SMFI was their true employer and Hua Tong a mere labor-only contractor. 2. Procedural History: The Executive Labor Arbiter dismissed the complaint for illegal dismissal but ordered Hua Tong to pay separation pay and nominal damages. The National Labor Relations Commission (NLRC) denied petitioners' appeal and their subsequent motion for reconsideration. Petitioners received the NLRC's Resolution on October 11, 2022, giving them until December 10, 2022, to file a petition for certiorari with the Court of Appeals (CA). 3. The Petition: On December 5, 2022, petitioners filed a Motion for Extension of Time with the CA, seeking an additional 30 days to file their petition for certiorari under Rule 65 of the Rules of Court. They cited the alleged abandonment by their former counsel, Atty. Geneses R. Abot, despite advance payment, and their subsequent difficulty in securing new legal representation. The CA denied this motion in a Resolution dated January 16, 2023, leading to the dismissal of their petition. A subsequent Motion for Reconsideration was also denied by the CA on May 26, 2023. This present petition for review on certiorari under Rule 45 of the Rules of Court assails these CA Resolutions, arguing that the CA erred in dismissing their petition for certiorari.
Issue(s)
Whether the Court of Appeals erred in dismissing Fajardo et al.'s petition for certiorari, considering the circumstances and potential injustice. Whether the CA gravely abused its discretion in denying the motion for extension of time to file the petition for certiorari, especially in light of the petitioners' circumstances and the alleged abandonment by their former counsel.
Ruling
The Petition for Review on Certiorari is GRANTED. The Resolutions dated January 16, 2023 and May 26, 2023 of the Court of Appeals in CA-G.R. SP No. 176393 are REVERSED and SET ASIDE. CA-G.R. SP No. 176393 is REINSTATED, with instructions for the Court of Appeals to process and resolve the same with deliberate dispatch. The matter of Atty. Geneses R. Abot's administrative liability is referred to the Commission on Bar Discipline of the Integrated Bar of the Philippines for investigation.
Ratio Decidendi
On the CA's dismissal of the petition for certiorari: The Court found merit in the petition, reversing the CA's resolutions. The CA erred in dismissing the petition for certiorari solely on the basis of the denial of the motion for extension of time. The Supreme Court emphasized that while the 60-day period for filing a certiorari petition is generally inextendible, exceptions exist for compelling reasons and to serve substantial justice. The Court invoked the principle that "those who have less in life should have more in law" to justify relaxing procedural rules in this instance, preventing a potential miscarriage of justice and upholding the right to due process. The Court stressed the need to balance speedy disposition of cases with the right of litigants to be heard. On the CA's denial of the motion for extension of time: The Court disagreed with the CA's assessment that Fajardo et al. did not exert enough effort to secure new counsel, considering their status as minimum wage workers who may not easily switch lawyers and are unfamiliar with procedural intricacies. The Court held that their failure to immediately secure new counsel should not be construed as a lack of effort, especially given the alleged abandonment by their former counsel. The Court also noted that the merits of the underlying illegal dismissal case were still to be determined by the CA, further supporting the need to address the procedural issues.
Main Doctrine
A motion for extension of time to file a petition for certiorari must be anchored on special or compelling reasons, and the strict application of procedural rules may be relaxed to serve substantial justice, especially when a litigant's right to due process is at risk due to the negligence or abandonment by counsel.