G.R. No. 100728 - JovellaNo.vs. Court of Appeals

Christian Children’s Fund, Inc. (CCF) is the petitioner, while the respondents include the National Labor Relations Commission (NLRC), Labor Arbiter Ricardo Olairez, and five private employees (Elizabeth Salao, Felisa Mamaril, Felipa Pitok, Joy Gonsoden, and Elena Eclarino).
The dispute centers on whether CCF is truly the employer of the private respondents or if the employment relationship lies with the Cristo Regis Center, an organization that is not incorporated and is operationally distinct from CCF.

Labor Arbiter Ricardo N. Olairez rendered a decision on April 30, 1986, ordering CCF to pay various backwages, separation pay, and other financial awards to the respondents, computed to a grand total of approximately ₱160,745.74, plus attorney’s fees.
CCF received notice of the labor arbiter’s decision on May 15, 1986. The appeal was filed by sending a Memorandum of Appeal and Motion for Reconsideration by registered mail on May 24, 1986, which, by law, is deemed filed on that mailing date.
Despite the registered-mail proof, the NLRC dismissed CCF’s appeal on the ground of late filing, considering the receipt date (May 30, 1986) as the filing date.
CCF’s subsequent motion for reconsideration of the NLRC’s resolution was denied on April 18, 1988.
On August 31, 1988, a temporary restraining order was issued against CCF, requiring it to post a bond of ₱25,000.00.

A contract exists between CCF and the Cristo Regis Center (the “Project”) establishing a financial and programmatic support relationship for a charitable project aimed at assisting children and their families.
Key provisions of the contract clarify that:

There exists no formal legal employment or agency relationship between CCF and the Cristo Regis Center.
The Cristo Regis Center is explicitly stated to be independent and not an agent of CCF, and has no authority to bind or pledge credit on behalf of CCF.
The contract, initially valid for five years and renewed three times, mandated that either party could terminate the agreement if its provisions were violated.
Management of the Cristo Regis Center was entrusted to the Benedictine Sisters, who later ceased their involvement in 1984.

CCF contends that it is not the real employer of the private respondents because:

The private respondents were hired and managed by the Cristo Regis Center.
Its financial and administrative functions are entirely separate from those of the Project.

The petitioner also challenges the dismissal of its appeal by the NLRC, arguing that the appeal was timely filed based on the mailing date.
Finally, CCF denies any liability regarding the alleged illegal dismissal of the private respondents, asserting that the closure of the Cristo Regis Center was inevitable and justified.

Whether or not Christian Children’s Fund, Inc. is the real employer of the private respondents, or if the employment relationship exists with the Cristo Regis Center.

Whether the NLRC committed grave abuse of discretion by dismissing CCF’s appeal on the basis that it was filed beyond the ten-day reglementary period, given that the appeal was posted by registered mail.

Whether the private respondents were illegally dismissed, considering that their termination coincided with the inevitable project closure of the Cristo Regis Center.