Case Digest (G.R. No. 111929)
Facts:
The case involves American Home Assurance Company, Inc. and Leslie J. Mouat as petitioners against the National Labor Relations Commission (NLRC), Labor Arbiter Manuel R. Caday, and private respondents Virgilio Malinao, Rosemilo Gacusan, and Dominador Loriaga. The events leading to this case began on June 6, 1991, when Malinao, Gacusan, and Loriaga filed a complaint for regularization, sick leave pay, vacation leave pay, and night shift differential pay against the petitioners before the National Capital Region Arbitration Branch of the NLRC. On July 10, 1991, the petitioners filed a Motion to Dismiss concerning Malinao and Gacusan, claiming that a compromise agreement had settled the case. However, on August 5, 1991, Malinao and Loriaga filed an amended complaint for illegal dismissal and service incentive leave. The petitioners' motion to dismiss was opposed by Malinao and Gacusan, who alleged that they were misled into signing the compromise agreement.
On February 1...
Case Digest (G.R. No. 111929)
Facts:
Filing of Complaint: On June 6, 1991, private respondents Virgilio Malinao, Rosemilo Gacusan, and Dominador Loriaga filed a complaint against petitioners American Home Assurance Company and/or Leslie Mouat for regularization, sick leave pay, vacation leave pay, and night shift differential pay before the National Capital Region Arbitration Branch of the NLRC.
Motion to Dismiss: On July 10, 1991, petitioners filed a Motion to Dismiss regarding Malinao and Gacusan, alleging that a compromise agreement had settled the case.
Amended Complaint: On August 5, 1991, Malinao and Loriaga filed an Amended Complaint for illegal dismissal and service incentive leave.
Opposition to Motion to Dismiss: On August 16, 1991, Malinao and Gacusan opposed the Motion to Dismiss, claiming that the compromise agreement was signed under undue influence and trickery.
Labor Arbiter’s Order: On February 13, 1992, Labor Arbiter Manuel R. Caday denied the Motion to Dismiss and ordered the return of the settlement money by Malinao and Gacusan.
Urgent Motion to Dismiss: On April 6, 1992, petitioners filed an Urgent Motion to Dismiss due to Malinao and Gacusan’s failure to return the settlement money.
Dismissal with Prejudice: On April 30, 1992, Labor Arbiter Caday dismissed the case with prejudice against Malinao and Gacusan but allowed Loriaga’s case to proceed.
Withdrawal of Counsel: On June 5, 1992, Atty. Albert G. Fanoga withdrew as counsel for the private respondents.
Dismissal of Loriaga’s Case: On August 11, 1992, Loriaga’s case was dismissed without prejudice upon his own motion.
Motion for Reconsideration: On December 14, 1992, Malinao filed a Motion to Admit the Motion for Reconsideration, which was treated as an appeal and elevated to the NLRC.
NLRC Resolution: On June 30, 1993, the NLRC set aside the Labor Arbiter’s Order and directed the hearing of the monetary claims on their merits.
Motion for Reconsideration Denied: On August 30, 1993, the NLRC denied petitioners’ Motion for Reconsideration.
Issue:
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Ruling:
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Ratio:
- Finality of Orders: The Labor Arbiter’s Order dismissing the case with prejudice against Malinao and Gacusan became final and executory due to their failure to appeal within the reglementary period.
- Quitclaim and Settlement: The execution of a quitclaim by Gacusan, coupled with the receipt of financial assistance, extinguished petitioners’ liability, barring further claims.
- Voluntary Dismissal: Loriaga’s voluntary motion for dismissal without prejudice precluded the NLRC from reinstating his case.
- Jurisdictional Period for Appeals: The NLRC lacked jurisdiction to entertain the belated Motion for Reconsideration, as it was filed beyond the 10-day period mandated by Article 223 of the Labor Code.
- Substantial Justice: The NLRC’s reliance on “substantial justice” was misplaced, as the circumstances did not justify deviating from the strict compliance with procedural rules.