G.R. No. L-11302 - People vs. Aguilar y Perez

Camara Shoes, a single proprietorship engaged in the manufacture and sale of shoes, was represented by Lucia Vda. de Camara.
The private respondents, numbering twenty (20), were regular employees of Camara Shoes.

On December 22, 1979, the petitioner served a notice to lay off the respondents effective January 31, 1980, subject to approval of a clearance application.
On December 28, 1979, the petitioner filed an application for clearance to terminate the services of its employees on the ground of alleged financial losses, business reversals, and lack of work due to a raw material shortage.

On January 11, 1980, the respondent union – Kapisanan ng mga Manggagawa sa Camara Shoes – filed its opposition to the clearance application.
Simultaneously, the union and the individual respondents filed a complaint for illegal lay-off, unpaid wages, and unpaid service incentive leave.
Two separate dockets emerged: one for the clearance/application issue (NCR-STF-1-281-80) and another for the labor complaint (NCR-STF-1-234-80).

On February 1, 1980, the petitioner denied further work by the individual respondents.
On March 28, 1980, the Director of Labor denied the petitioner’s clearance application due to lack of substantial proof.
The Director’s decision ordered the reinstatement of the affected employees with full backwages from February 1, 1980 up to actual reinstatement, as well as payment of five (5) days service incentive leave for the year 1979.

On April 18, 1980, the petitioner appealed the Director’s order to the National Labor Relations Commission (NLRC).
Meanwhile, on June 11, 1980, the petitioner moved to dismiss the pending cases for sixteen of the individual respondents who had settled their claims via an affidavit.
On July 3, 1980, the respondent union moved to dismiss the appeal on the ground that it was filed out of time.

The NLRC dismissed the appeal as untimely on December 29, 1982, holding that the appeal should have been filed within ten (10) working days from receipt (April 2, 1980) – specifically not after April 16, 1980.
The petitioner contended that holidays (Maundy Thursday, Good Friday, and other non-working days) should not count, thus extending the appeal period.
The computation provided by the petitioner accounted for the exclusion of non-working days and designated holidays, arguing that the appeal, dated April 18, 1980, was filed within the calculated ten working days.

The petitioner argued that its business was in a state of bankruptcy with heavily mortgaged properties, necessitating the termination of employees to minimize losses and meet financial obligations.
Evidence presented included a statement of assets and liabilities and an allegation that the employee termination was to avoid further losses.
The Director of Labor, however, dismissed the clearance application due to the petitioner’s failure to produce sufficient evidence verifying the business’s claimed financial losses or bankruptcy.

The petitioner asserted that the death of its proprietor, Santos Camara, who died intestate on January 13, 1979, should automatically extinguish the labor cases.
This argument was rejected on the basis that the employee claims related to reinstatement and backwages emerged after the proprietor’s death and fell under the exclusive jurisdiction of labor authorities, independent of a money claim.

Was the appeal to the NLRC filed timely, taking into account the appropriate computation of ten (10) working days, exclusive of holidays and non-working days?
Did the NLRC properly consider the intervening holidays and weekends when determining the timely filing of the appeal?

Did the petitioner (Camara Shoes) sufficiently prove that its business was in a state of bankruptcy with significant financial losses to justify the termination of the employees?
Was the alleged need to prevent further losses adequately demonstrated by the evidence submitted?

Does the death of the company’s proprietor, Santos Camara, automatically extinguish the individual labor claims filed by the employees?
Is the termination and subsequent labor case still actionable even after the proprietor’s death?