G.R. No. 197074 - Citibank, N.A. vs. Andres

Respondents Priscila B. Andres and Pedro S. Cabusay, Jr. were employed by petitioner Citibank, N.A. as Reconciliation Officer and SpeedCollect Officer, respectively, in the SpeedCollect Unit.
The SpeedCollect Unit was responsible for implementing, monitoring, and documenting the collection and crediting of payments from the bank’s clients.

On November 5, 2002, a client complained that check payments were not being properly credited.
In response, petitioner launched an internal investigation that included a fact-finding interview, in which the respondents voluntarily participated.
Following the interview, the case was referred to the Citigroup Security Investigative Services (CSIS), which conducted further investigation and filed a report alleging misconduct by the respondents.
Eulalia M. Herrera, Vice-President of petitioner’s Human Resources Department, separately informed each respondent that formal administrative proceedings would be initiated.
Respondents were warned that if found guilty of misconduct, they would face termination with the termination being reported to the Bangko Sentral ng Pilipinas.
In view of these potential consequences, respondents submitted their respective resignation letters effective April 2 and 3, 2003.

Following their resignation, respondents filed a complaint for constructive dismissal before the Labor Arbiter (LA), seeking moral and exemplary damages as well as attorney’s fees.
The LA dismissed the complaint in its Decision dated December 29, 2003.
Respondents then appealed to the National Labor Relations Commission (NLRC). On October 20, 2005, the NLRC First Division reversed the LA decision and ruled in the respondents’ favor.
Petitioner filed for reconsideration, which was denied by the NLRC First Division in its Resolution dated December 28, 2007, later served by mail on February 15, 2008.
The NLRC First Division subsequently issued an Entry of Judgment on April 18, 2008.

Respondents promptly moved for the execution of the NLRC ruling on May 12, 2008.
On June 25, 2008, petitioner filed an urgent motion to set aside the finality of the judgment, asserting that it never received copies of the December Resolution, Entry of Judgment, and Notice of Hearing due to errors in service and the withdrawal of its previous counsel, PECABAR.
Owing to these alleged due process failures and the service irregularities, the NLRC Second Division, by its Decision dated March 31, 2009, set aside the finality of the December Resolution and Entry of Judgment.
The NLRC Second Division reasoned that the non-receipt of proper notice violated Section 6, Rule III of the NLRC Rules of Procedure, thereby necessitating that petitioner be given another opportunity to present its case.

Respondents filed a petition for certiorari before the CA (First CA Petition) to challenge the NLRC Second Division’s ruling.
Shortly thereafter, petitioner filed its own petition for certiorari before the CA (Second CA Petition) to contest the October Decision and December Resolution of the NLRC First Division.
The First CA Petition was raffled to the CA’s Special Fifteenth Division, and on January 12, 2011, it rendered a decision annulling and setting aside the NLRC rulings.
The CA noted that petitioner’s previous counsel, PECABAR, failed to serve proper notice of its withdrawal, and that petitioner’s present counsel, RMBSA, was negligent in its inquiry into the case records.
Petitioner filed a motion for reconsideration of the CA decision, which was denied.
Separately, on July 12, 2011, the CA’s Special Eleventh Division granted the Second CA Petition by setting aside the NLRC First Division ruling and reinstating the LA’s decision.
Respondents then filed a petition for review on certiorari before the Supreme Court questioning the ruling of the Special Eleventh Division, leading to further procedural developments.

The instant petition before the Supreme Court asked whether the December Resolution and the Entry of Judgment issued by the NLRC First Division should be set aside.
The Court was faced with reconciling the conflicting CA decisions: one from the Special Fifteenth Division (which annulled NLRC rulings) and the other from the Special Eleventh Division (which reinstated the LA decision and NLRC First Division ruling).
The Supreme Court recognized that these conflicting rulings created a dilemma concerning the finality and enforceability of the respective decisions.

Whether the NLRC’s December Resolution and Entry of Judgment, issued by the NLRC First Division, should be set aside on the ground that petitioner was denied proper notice and due process.

Did petitioner receive adequate notice of the December Resolution, Entry of Judgment, and Notice of Hearing?
Was petitioner deprived of its right to due process due to the alleged irregularities in service and counsel’s withdrawal?

How should the conflicting rulings of the Court of Appeals (from the Special Fifteenth Division and the Special Eleventh Division) be reconciled?

Should the petition before the Supreme Court honor the ruling that waived the finality of the NLRC decision or maintain the final and executory decision that resulted from the consolidation of matters in the NLRC and CA proceedings?
In view of the doctrine of the immutability of judgment, is there any ground to disturb the final CA decision already affirmed in related proceedings (G.R. No. 201344)?