Facts:

This case involves Banahaw Broadcasting Corporation (BBC) as the petitioner against various respondents, including Cayetano Pacana III, Noe U. Dacer, and others, collectively referred to as the DXWG personnel, who are employees of the DXWG-Iligan City radio station. On August 29, 1995, the DXWG personnel filed a complaint for illegal dismissal, unfair labor practices, reimbursement of unpaid Collective Bargaining Agreement (CBA) benefits, and attorney's fees against both BBC and the Intercontinental Broadcasting Corporation (IBC).

Labor Arbiter Abdullah L. Alug issued a favorable decision on June 21, 1996, directing BBC to pay the DXWG personnel unpaid CBA benefits amounting to ₱12,002,157.28, which included wages, 13th-month pay, and various allowances. Following appeals from both parties, the National Labor Relations Commission (NLRC) dismissed the case as to IBC on April 21, 1997, due to a motion claiming that IBC was not the employer. BBC's subsequent appeals led to

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Facts:

Background of the Case

• This case arises from a Petition for Review on Certiorari under Rule 45 of the 1997 Rules of Civil Procedure challenging earlier dispositions.
• The dispute involves Banahaw Broadcasting Corporation (BBC), the petitioner, and a group of supervisory and rank-and-file personnel (DXWG personnel) who are employees of the DXWG-Iligan City radio station.
• The radio station is owned by BBC, which is managed by Intercontinental Broadcasting Corporation (IBC).

Factual and Procedural Antecedents

• On August 29, 1995, the DXWG personnel filed a complaint with the Sub-regional Arbitration Branch No. XI in Iligan City for illegal dismissal, unfair labor practice, reimbursement of unpaid Collective Bargaining Agreement (CBA) benefits, and attorney’s fees against both IBC and BBC.
• On June 21, 1996, Labor Arbiter Abdullah L. Alug rendered a decision awarding the personnel a total of P12,002,157.28 in unpaid CBA benefits.
• The Labor Arbiter denied claims for other benefits such as Christmas bonus, educational assistance, and medical expenses.
• Both parties subsequently appealed to the National Labor Relations Commission (NLRC).
• On May 15, 1997, a joint Motion to Dismiss, Release, Waiver, and Quitclaim was filed by IBC and the DXWG personnel, resulting in the dismissal of issues against IBC.
• BBC then filed a Motion for Reconsideration alleging procedural irregularities, including claims that neither it nor its authorized representatives were properly served; that the liability of IBC and BBC was solidary; that IBC effected the termination of employment; that the personnel were members of the IBC union; and that BBC’s sequestered properties could not be levied.
• On December 12, 1997, the NLRC vacated the Labor Arbiter’s decision and remanded the case due to irregular service against BBC.
• On October 15, 1998, Labor Arbiter Nicodemus G. Palangan rendered his decision, again holding BBC liable for the same monetary award previously computed.
• BBC and the DXWG personnel both appealed anew to the NLRC.
• The DXWG personnel reasserted claims regarding unpaid benefits and challenged the computation of the award.
• BBC, in its Memorandum of Appeal, challenged the award on the ground that the benefits were only due to IBC employees and filed a Motion for the Recomputation of the Monetary Award to reduce its required appeal bond.
• On September 16, 1999, the NLRC denied BBC’s Motion for Recomputation and ordered BBC to post an appeal bond within ten (10) days, warning that failure to do so would result in dismissal of the appeal.
• Instead of complying, BBC filed a Motion for Reconsideration alleging its exemption from posting an appeal bond because it is wholly owned by the Republic of the Philippines.
• On November 22, 1999, the NLRC dismissed BBC’s appeal for non-perfection after failing to post the bond, and dismissed the DXWG personnel’s appeal for lack of merit.
• Following a further Motion for Reconsideration by BBC which was denied on January 13, 2000, BBC filed a Petition for Certiorari with the Court of Appeals, which eventually rendered a decision on April 15, 2005 denying the petition.
• The Court of Appeals affirmed the NLRC ruling by holding that BBC, even though government-owned, has a separate corporate personality from the Republic and is engaged primarily in commercial radio and television broadcasting.
• The case’s factual background is further complicated by the history of BBC’s ownership; originally privately owned, BBC was later sequestered along with IBC and Radio Philippines Network (RPN-9) and transferred to government control following a compromise agreement executed between Roberto S. Benedicto and the Republic.
• Despite being government-owned at the time of the filing of the complaint, BBC’s primary function as defined in its Amended Articles of Incorporation is purely commercial.

Nature of the Controversy

• The central dispute is whether BBC should be granted exemption from posting an appeal bond as required by law when appealing a monetary award.
• BBC asserts that, as a government-owned corporation, it should be presumed solvent and exempt from this requirement.
• Respondents and the lower courts maintain that despite government ownership, BBC’s engagement in commercial activities disqualifies it from such an exemption, making the posting of the appeal bond a strict and jurisdictional requirement.

Issue:

• Whether BBC, though entirely government-owned following sequestration and transfer of assets, qualifies as a governmental agency or instrumentality exempt from the mandatory posting of an appeal bond under the law.
• Whether the filing of motions for recomputation of the monetary award and for reconsideration by BBC could be construed as extending the period for perfecting its appeal, in light of the strict rule mandating the timely posting of an appeal bond.
• Whether the dismissals by the NLRC (and the subsequent affirmations by the Court of Appeals) of BBC’s appeal on the ground of non-perfection (failure to post an appeal bond) constitute grave abuse of discretion or procedural error.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)