Facts:

The case involves six petitioners—Emma Cordova, Ginaly Arnuza, Lerma Plazon, Joann Gamil, Teresita Torion, and Nene Janiola—who were former employees of Keysa's Boutique owned by Cris and Eleanor Albaran, the respondents. The events leading to the litigation took place in Butuan City, with the relevant timeline beginning on November 10, 1997, when the petitioners requested their salaries to be increased in line with the then-prevailing minimum wage of P103.00. They also sought the payment of their unpaid 13th month pay since the commencement of their employment. The respondents reportedly responded dismissively to these requests, with Cris Albaran asserting, "I am the owner, and I will be the one to decide."

Following their demand, Nene Janiola was dismissed on November 15, 1997, with Ginaly Arnuza and Joann Gamil facing similar dismissals on November 25, followed by Emma Cordova, Lerma Plazon, and Teresita Torion on November 28, 1997. The petitioners then filed a

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Facts:

Background of Employment and Claims

• Petitioners were former employees of Keysa’s Boutique, located at G. Flores Ave., Butuan City.
• The employment records presented by petitioners detailed:
• Employment start dates, job designations, working hours (8 a.m. to 7 p.m.), and monthly salaries.
• Specific names and corresponding dates:

- Emma Cordova – started August 1, 1992; Salesgirl; P2,500/month. - Lerma Plazon – started July 1, 1996; Salesgirl; P1,200/month. - Teresita Torion – started August 1, 1996; Salesgirl; P1,200/month. - Joann Gamil – started November 6, 1995; Salesgirl; P1,200/month. - Ginaly Arnuza – started July 1, 1997; Salesgirl; P1,200/month. - Nene Janiola – started June 1, 1997; Salesgirl; P1,000/month.

Sequence of Dismissals and Filing of Complaints

• Dismissals occurred on distinct dates:
• November 15, 1997 – Nene Janiola was dismissed.
• November 25, 1997 – Ginaly Arnuza and Joann Gamil were dismissed.
• November 28, 1997 – Emma Cordova, Lerma Plazon, and Teresita Torion were terminated.
• Petitioners filed complaints before the Regional Arbitration Branch of the Department of Labor and Employment in Butuan City asserting:
• Illegal dismissal.
• Non-payment/underpayment of wages, overtime pay, 13th month pay, and service incentive leave pay.
• That as regular employees, they were entitled to security of tenure and could be terminated only for just or authorized causes.

Adjudicatory Proceedings and Bond Issues

• Procedural history:
• The Labor Arbiter, on April 14, 1998, ruled in favor of the petitioners, declaring their dismissal illegal and awarding a total monetary compensation of P384,352.15.
• Respondents failed to submit their position paper and instead later appealed the Labor Arbiter’s decision.
• Bond posting issues:
• Respondents sought to reduce the appeal bond on the basis of financial distress.

- They submitted a bank certification from RCBC indicating a savings account balance of P23,008.19. - Dismissing the illegal dismissal claim for three of the petitioners while declaring the dismissal illegal for the remaining petitioners. - Awarding different monetary amounts as shown in the attached annex of the decision. - Petitioners contended that respondents failed to post the required appeal bond. - Respondents, appealing the Labor Arbiter’s monetary award, submitted a “Most Urgent Plea To Reduce Cash Bond” citing financial difficulties, and executed a Deed of Assignment to secure a P50,000 bond. - It accepted the reduction of the bond to P50,000. - It ruled that the Labor Arbiter’s April 14, 1998 decision did not become final due to respondents’ failure to post a proper appeal bond.

Issue:

Compliance with Bond Requirements

• Whether the submission of a bank certification by the respondents, in lieu of a cash or surety bond, satisfies the mandatory requirement under Art. 223 of the Labor Code for perfecting an appeal involving a monetary award.
• Whether such certification is sufficient to ensure the payment of the adjudged award if the appeal fails.

Finality and Jurisdictional Implications

• Whether the failure of respondents to post the required cash or surety bond renders the April 14, 1998 decision of the Labor Arbiter final and executory.
• Whether the NLRC and the Court of Appeals had jurisdiction to review or revise the Labor Arbiter’s decision in light of the bond posting deficiency.

Adequacy and Purpose of the Supersedeas Bond

• Whether the proper purpose of the appeal bond—to safeguard the payment of the monetary award—was undermined by the respondents’ submission of only a bank certification.
• Whether the financial limitations of the respondents justify a deviation from the strict bond requirement.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)