Case Digest (G.R. No. 117442-43)
Facts:
Fem's Elegance Lodging House, Fenitha Saavedra and Iries Anthony Saavedra v. The Honorable Leon P. Murillo, Labor Arbiter, Regional Arbitration Branch, Region X, National Labor Relations Commission, Cagayan de Oro City, et al., G.R. Nos. 117442-43, January 11, 1995, First Division, Quiason, J., writing for the Court.
Petitioners Fem's Elegance Lodging House (owned by Fenitha Saavedra and managed by Iries Anthony Saavedra) are employers who terminated several employees between March and April 1994. The terminated employees (private respondents) separately filed two labor cases for unpaid benefits — minimum wage, overtime, rest day pay, holiday pay, thirteenth-month pay and separation pay — before the National Labor Relations Commission, Regional Arbitration Branch No. X, docketed as NLRC RAB X Cases Nos. 10-04-00232(-00233)-94.
A pre-arbitration conference was held on May 31, 1994, where the parties agreed to consolidate the two cases and to file simultaneous position papers within thirty days (until June 30, 1994), after which the cases would be deemed submitted. Petitioners filed their position paper on June 29, 1994. When petitioners inquired on July 7, the NLRC receiving clerk reported that private respondents had not yet filed their position papers. Petitioners then filed a Motion to Dismiss on July 8 for respondents’ failure to comply with the agreed schedule.
Private respondents belatedly filed their position paper on July 15, 1994; petitioners filed a Motion to Expunge on July 18. The Labor Arbiter set a clarificatory hearing for September 7 and, after petitioners sought resolution of their motions, issued an Order on September 21, 1994 denying petitioners’ motions. The Labor Arbiter ruled that a fifteen-day delay was not unreasonable, invoked the principle that technicalities should not defeat substantive rights, and relied on Article 4 of the Labor Code and the principle of exclusio unius est exclusio alterius in observing that a delay was not a ground for dismissal under Section 15, Rule 5 of the Revised Rules of Court.
Petitioners filed a petition for certiorari under Rule 65 of the Rules of Court (with a temporary restraining order) charging the Labor Arbiter with grave abuse o...(Pro-only)
Issues:
- Did petitioners fail to exhaust administrative remedies so as to render their Rule 65 petition premature?
- Did the Labor Arbiter commit grave abuse of discretion in denying petitioners’ Motion to Dismiss and Motion to Expunge for private respondents’ late filing of th...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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