G.R. No. 157907 - Chronicle Securities Corp. vs. National Labor Relations Commission

In September 1993, petitioners hired private respondent Neal H. Cruz as publicist and editor-in-chief for the Manila Chronicle.
His compensation package included a monthly salary of P60,000.00 plus the provision of a brand new car.

After resigning from his previous assignment at Today newspaper, Cruz assumed his role at the Manila Chronicle with the task of revitalizing its image.
He introduced innovative measures such as the use of full-color printing and the addition of new columns and sections, which subsequently improved circulation and increased advertising revenues.

In July 1994, after the publication of a controversial article attributed to his editorial oversight, petitioners terminated Cruz’s employment.
In response, Cruz filed a complaint for illegal dismissal, challenging the termination as unjust.

On January 2, 1997, Labor Arbiter Ariel C. Santos rendered a decision holding petitioners liable for illegal dismissal.
The decree ordered the following relief:

Immediate reinstatement to the position of Editor-in-Chief (or, alternatively, separation pay computed as one month’s salary for every year of service with full backwages).
The vehicle provided as part of Cruz’s compensation was awarded to him, since petitioners did not contest its inclusion.
Moral damages amounting to TEN MILLION PESOS (P10,000,000.00) for mental anguish, social shock, and besmirched reputation.
Exemplary damages of FIVE MILLION PESOS (P5,000,000.00) as a public corrective measure.
Attorney’s fees computed at 10% of the total award.

Petitioners appealed the Labor Arbiter’s decision with the National Labor Relations Commission (NLRC), which affirmed the decision with modifications by reducing the moral damages to P500,000.00 and exemplary damages to P200,000.00.
A motion for reconsideration by petitioners was denied on September 15, 1998.
Petitioners filed a petition for certiorari and prohibition with the Court of Appeals, which was later dismissed on May 4, 1999.
Following the NLRC’s issuance of the Writ of Execution on October 16, 1999, petitioners moved to quash the writ; however, this motion was denied on August 29, 2000.

On October 20, 2000, petitioners attempted to file their appeal within the prescribed period.
Due to a Luzon-wide power blackout, the NLRC office was already closed when petitioners arrived with the required documents.
Although a copy of the Notice of Appeal and Memorandum of Appeal was sent via registered mail from the Makati City Post Office, the physical filing at the NLRC was only accomplished on Monday, October 23, 2000.
The NLRC subsequently ruled the appeal as being filed out of time, and a motion for reconsideration was denied on August 20, 2001.

Petitioners contend that the delay in filing their appeal was due to extraordinary circumstances beyond their control and not due to any fault on their part.
They also challenge the method of computing backwages, arguing that it erroneously extends beyond the termination period during which reinstatement was feasible—given that the Manila Chronicle permanently ceased publication on January 19, 1998.

The Labor Arbiter computed backwages from September 15, 1994, to September 15, 2000, alongside additional awards for separation pay, moral and exemplary damages, and attorney’s fees.
Petitioners objected on the ground that the computation should end on January 19, 1998, when the newspaper’s operations ceased, rendering reinstatement impossible.

Whether the delay in filing the appeal with the NLRC can be excused given the extraordinary circumstances (specifically, the Luzon-wide power blackout) that prevented petitioners from filing on time.

Whether the backwages due to private respondent Neal Cruz were improperly computed by extending beyond the closure of the Manila Chronicle, thereby including a period during which reinstatement was no longer feasible.