G.R. No. 187491 - Far East Bank and Trust Co. vs. Chua

Lilia S. Chua was employed by Far East Bank and Trust Company and rose through the ranks to become Assistant Vice President, a position she held since October 1, 1997.
On July 1, 1999, Chua’s employment was terminated on the ground that she engaged in multiple kiting transactions—fraudulent drawings from bank accounts lacking sufficient funds—thus allegedly breaching the bank’s Code of Conduct.

Challenging her termination, Chua filed a Complaint for illegal dismissal and monetary claims before the Regional Arbitration Branch XII in Cotabato City of the National Labor Relations Commission (NLRC).
In the subsequent proceedings, both parties were required to submit Position Papers; however, despite an extension, Far East Bank failed to timely file its Position Paper.
On April 25, 2000, Executive Labor Arbiter Quintin B. Cueto III rendered a decision declaring Chua’s dismissal illegal, awarding her reinstatement and full backwages (totaling P1,181,804.19), among other incidental benefits.

Following the Arbiter’s decision, Far East Bank filed a Motion to admit its Position Paper on the same day, which was denied on May 15, 2000.
Subsequently, on May 25, 2000, Far East Bank directly filed its Notice of Appeal and Memorandum of Appeal with the NLRC instead of with the Regional Arbitration Branch wherein the decision was rendered.
The NLRC Fifth Division reversed the Labor Arbiter’s ruling on April 30, 2001, holding that the bank’s slight delay in filing its Position Paper was excusable and that Chua’s irregular acts justified her dismissal.

Chua, dissatisfied with the NLRC’s resolution, filed a Motion for Reconsideration on May 25, 2001, arguing that the Commission had overlooked proper issues regarding the order of presentation and relied improperly on the bank’s Position Paper.
When her Motion for Reconsideration was denied in a Resolution dated December 21, 2001, Chua elevated the matter by filing a Petition for Certiorari under Rule 65 before the Court of Appeals.
The crux of Chua’s petition centered on the issue that Far East Bank’s appeal was directly filed with the NLRC rather than with the Regional Arbitration Branch, allegedly violating procedural requirements.

Petitioner (Far East Bank) maintained that its direct filing before the NLRC was within the agency’s discretion, contending that substantial justice in labor cases should prevail over minor technical lapses.
Respondent (Chua) argued that the failure to file the memorandum of appeal with the proper venue (i.e., the Regional Arbitration Branch) rendered the bank’s appeal unperfected.
Additionally, Chua asserted that the NLRC had acted without or in excess of jurisdiction by entertaining a directly filed appeal that did not comply with Rule VI, Section 3 and Section 4 of its Rules of Procedure.

Whether Far East Bank’s appeal, having been directly filed with the NLRC rather than with the Regional Arbitration Branch, was perfected despite the violation of the prescribed venue requirement.

Whether the venue error in filing the memorandum of appeal is a fatal defect that automatically deems the appeal unperfected.
Whether the liberal interpretation of technical requirements in labor cases, in light of substantial justice, allows for the overlook of such procedural lapses.
Whether respondent, by failing to timely raise the issue of jurisdiction as required, is estopped from invoking it later on appeal.