G.R. No. 172538 - Esperida vs. Jurado Jr.

Petitioners (Isabelo Esperida, Lorenzo Hipolito, and Romeo de Belen) filed a Complaint for illegal dismissal against respondent Franco K. Jurado, Jr. before the Labor Arbiter on February 5, 2001.
The Labor Arbiter rendered a Decision on March 14, 2002, ruling in favor of the petitioners by declaring their illegal dismissal and awarding backwages and separation pay.
Respondent appealed the decision with the National Labor Relations Commission (NLRC), but the NLRC issued a Resolution affirming the Labor Arbiter’s decision.
Respondent then elevated the appeal before the Court of Appeals (CA), where on December 13, 2004, the CA dismissed the petition and upheld the NLRC Resolution.
Following a motion for reconsideration by the respondent (denied on September 27, 2005), the respondent filed a Petition to Declare Petitioners in Contempt before the CA on July 21, 2005, alleging acts of dishonesty, fraud, and falsification of documents intended to mislead the CA in the underlying illegal dismissal case.

The CA found the petition to declare contempt sufficient in form and substance and issued a Resolution ordering petitioners to file an Answer within 15 days to show cause why they should not be found guilty of indirect contempt.
On February 8, 2006, counsel for petitioners filed an entry of appearance along with a motion for extension of time, requesting additional days (up to February 18, 2006) to file their Answer.
On March 2, 2006, the CA issued a Resolution denying the motion for extension on the ground that:

The motion was filed by mail on February 8, 2006, even though the designated deadline for filing was February 3, 2006.
The motion lacked a sufficient explanation as to why the service and filing were not effected personally.

Despite filing a Second Motion for Extension on February 21, 2006, and an Omnibus Motion on March 20, 2006—with explanations regarding workload, delays in mailing, and distance issues causing non-personal service—the CA on April 19, 2006, denied both motions.
The CA also declared the case as "submitted for resolution" without receiving the petitioners’ Answer, effectively barring them from having the opportunity to respond to the contempt charges.

Petitioners challenged the CA’s strict application of the rules and the denial of their extension and reconsideration motions, arguing that:

Their explanations and the subsequent filing of their Answer should prompt a liberal and equitable interpretation of the rules.
Denying the Answer and treating the affairs as final would deprive them of their right to due process and fair opportunity to be heard.

Respondent maintained that the CA properly applied the procedural rules regarding the timely filing of pleadings and denied any violation of due process, asserting that his own right against being declared in contempt was adequately protected under the Rules of Court.

Whether the Court of Appeals erred in denying the motions for extension filed by petitioners for the submission of their Answer in connection with the contempt proceedings.
Whether the CA violated the petitioners’ due process rights by deeming the case as submitted for resolution without affording them the required opportunity to be heard or to file an Answer to the contempt charge.
Whether the CA committed an error in denying the motions for reconsideration and admission of petitioners’ Answer, given the circumstances cited in their justifications and the principle of substantial compliance in procedural matters.