G.R. No. 117983 - Uy vs. National Labor Relations Commission

On June 28, 2004, petitioner Barangay Dasmariñas, represented by Barangay Captain Ma. Encarnacion R. Legaspi, filed a Complaint-Affidavit before the Office of the Prosecutor of Makati (docketed as I.S. No. 04-F-10389).
The complaint charged respondent Creative Play Corner School (CPC) and its alleged owners – Dr. Amado J. Piamonte, Regina Piamonte Tambunting, Celine Concepcion Lebron, and Cecille Cuna Colina – with falsification and the use of falsified documents.
Petitioner alleged that the respondents had falsified and used a Barangay Clearance and an Official Receipt, which purportedly bore Legaspi’s signature and were issued by the Office of the Barangay Captain of Dasmariñas Village, Makati City.

In their respective counter-affidavits, Lebron and Colina denied involvement in any falsification, claiming that the allegation of their ownership of CPC was unproven and that no operative act incriminated them.
Tambunting and Piamonte echoed these defenses; Tambunting stated that no relevant office had received the documents, while Piamonte disclaimed any participation in the operations of CPC, contending that petitioner failed to discharge its burden of establishing probable cause.

On September 29, 2004, Assistant City Prosecutor Carolina Esguerra-Ochoa recommended dismissal of the case due to failure to establish probable cause.
The decision rested on the absence of police laboratory findings or law enforcement confirmations regarding the tampering or falsification of the documents.
The city prosecutor’s resolution was approved by City Prosecutor Feliciano Aspi and subsequently released on November 4, 2004, leading petitioner to seek a review before the Department of Justice (DOJ).

Proceedings Before the Department of Justice and Filing of the Petition for Review

Petitioner challenged the prosecutor’s finding by asserting that Legaspi’s signature was forged, thereby emphasizing her capacity to attest to the falsification.
Petitioner argued that accompanying documents—such as a sample Barangay Clearance and certification regarding the tampered official receipt—sufficiently established probable cause.
Despite these contentions, the DOJ dismissed the Petition for Review on February 21, 2005, also taking note that the motion was filed beyond the prescribed reglementary period.
A subsequent Motion for Reconsideration, filed on April 25, 2005, was likewise denied.

Prior to filing its petition for review before the Court of Appeals (CA), petitioner sought an extension of time; the CA granted a 15-day extension from May 13, 2005 until May 28, 2005 via Resolution dated May 23, 2005.
Petitioner then filed a Second Motion for Extension requesting an additional five days (until June 2, 2005) but subsequently filed the petition by mail on June 7, 2005—beyond the granted period.
The CA, citing Section 4, Rule 43 of the Rules of Court, held that only one extension of fifteen (15) days is permitted and that any further extension must be granted only for a most compelling reason.
Finding petitioner’s reasons (pressure due to heavy workload and a later claim of a sudden death in the family of counsel) unpersuasive, the CA denied the second extension and ultimately dismissed the Petition for Review.

Petitioner subsequently filed a Motion for Reconsideration, maintaining that the belated filing did not prejudice respondents since they were not detained and that the salient merits of the case should override technical defects.
Respondents reiterated that the technical defaults and repeated transgressions of procedural requirements invalidated petitioner’s claim.
On September 29, 2005, the CA issued a resolution reaffirming the denial of the extension request and dismissing the petition on procedural grounds.

Whether the dismissal of the Petition for Review solely on technical grounds—specifically, the belated filing beyond the extended period—is justified.
Whether petitioner’s repeated failure to adhere to the rules of procedure warrants a strict application of Section 4, Rule 43.

Whether the substantive allegations of falsification and the supporting documentary evidence establish sufficient probable cause for initiating a criminal case against the respondents.
Whether the CA was obligated to examine the substantive merits of the case even though the petition was filed out of time.

The Doctrine of Liberal Construction vs. Strict Adherence to Procedural Rules

Whether the policy of liberal construction of the Rules of Court can justify the relaxation of filing deadlines and technical requirements.
Whether the respondents’ right to procedural regularity and the need for an expeditious administration of justice outweigh the petitioner's arguments for substantive justice.

Whether any delay—specifically the ten-day period and successive motions for extension—resulted in any actual or demonstrable prejudice to the respondents.