G.R. No. 24978 - People vs. Ferdo

Wilson Aba, the petitioner, filed a complaint alleging illegal dismissal, along with claims for legal holiday pay, premium pay on holidays and rest days, service incentive leave pay, separation pay, and salary and 13th-month pay differentials against Hda. Sta. Ines and Alfonso Villegas.
Aba’s complaint stemmed from his assertion of having been employed at Hda. Sta. Ines starting from 26 December 1976 until his termination on 27 August 1990, the termination allegedly due to his union activities.
In a separate complaint filed against Hda. Fatima and/or Alfonso Villegas for underpayment of salaries, Aba claimed an employment period from 5 January 1972 until 6 December 1990, raising issues of overlapping employment.

Hda. Sta. Ines and Alfonso Villegas denied employing Aba and argued that simultaneous employment at Hda. Fatima and Hda. Sta. Ines was impossible, noting that the two establishments were approximately 15 kilometers apart.
To support their position, the respondents submitted a copy of the underpayment of salaries complaint and later affidavits from Hda. Sta. Ines personnel (including a timekeeper and a “cabo”) attesting to Aba’s lack of employment with them.
Additional documentary evidence included a decision from RAB Case No. 09-418-90-D (Cresencio Abriga, Sr. et al. v. Hda. Fatima and/or Alfonso Villegas), where Aba was awarded his 13th-month pay from Hda. Fatima.

On 17 November 1993, Labor Arbiter Geoffrey P. Villahermosa dismissed Aba’s initial complaint with prejudice due to the apparent inconsistency in the periods of employment.
Aba appealed the dismissal, arguing that the case, comprising issues of illegal dismissal and underpayment of salaries, should have been consolidated and decided on the merits.
On 10 March 1994, the NLRC remanded the case to the Labor Arbiter for a decision on the merits, prompting both parties to submit respective position papers.
During the remanded proceedings, Aba amended his claim by asserting employment with Hda. Sta. Ines from as early as 1968, while the private respondents maintained their denial and supported their position with additional affidavits and documentary evidence.

Aba’s appeal was eventually verified to have been filed within the reglementary period and contained the required assignment of errors, supporting arguments, and reliefs sought.
However, it was discovered that Aba initially failed to pay the appeal docketing fee, resulting in the NLRC dismissing his appeal on this ground.
Aba filed a Motion for Reconsideration (and later, a Supplemental Brief for the Complainant-Appellant) attaching further evidence, including affidavits from hacienda workers, in an attempt to rectify the record and challenge the dismissal on the basis of the delayed docket fee payment.

The Office of the Solicitor General intervened, contending that the dismissal solely due to the delayed payment of the appeal docketing fee was inconsistent with the constitutional mandate to protect labor and with settled jurisprudence.
The Solicitor General moved for the setting aside of the NLRC’s decision, arguing that the substantive merits of the case and the protective policies favoring labor should take precedence over a technical default in fee payment.

Whether the failure to pay the appeal docketing fee on time is fatal to the perfection of Aba’s appeal.
Whether the technical requirement of timely fee payment should override the substantive rights of a labor complainant in a case involving disputed employment status and alleged illegal dismissal.
Whether the NLRC’s dismissal based solely on the non-payment of the docketing fee was in consonance with the constitutional mandate and set jurisprudence protecting labor standards.