Case Digest (G.R. No. 153859)
Case Digest (G.R. No. 153859)
Facts:
Filipinas (Pre-Fabricated Bldg.) Systems "Filsystems,", Inc. and Felipe A. Cruz, Jr. v. National Labor Relations Commission and Cresenciano Bebanco, et al., G.R. No. 153859, December 11, 2003, Second Division, Puno, J., writing for the Court.Respondents (employees) filed a complaint for illegal dismissal and monetary claims (service incentive leave, 13th month pay, night shift differential) against petitioners before the National Labor Relations Commission; the case was assigned to Labor Arbiter Donato G. Quinto, Jr. The Arbiter ordered position papers; respondents complied but petitioners did not, and the Arbiter treated petitioners’ inaction as a waiver of their right to present evidence. The Labor Arbiter found for respondents on the merits, sustained illegal dismissal, ordered reinstatement, and granted the monetary claims.
Petitioners appealed to the NLRC and, for the first time, presented evidence asserting respondents were project employees dismissed due to the discontinuation of the Jaka Tower I project. Respondents argued the NLRC lacked jurisdiction because petitioners failed to post the appeal bond within the ten-day reglementary period; the NLRC nonetheless assumed jurisdiction and remanded the case to the Labor Arbiter for further proceedings. Respondents’ motion for reconsideration before the NLRC was denied.
Respondents then filed a petition for certiorari with the Court of Appeals, which held that the NLRC lacked jurisdiction because the appeal bond had been posted late and therefore reinstated the Labor Arbiter’s decision; the Court of Appeals denied petitioners’ motion for reconsideration. Petitioners sought relief in this Court by a petition for review on certiorari under Rule 45. The Supreme Court considered the timeliness of the appeal bond (petitioners received the Arbiter’s decision October 31, 1998; memorandum of appeal dated November 9, 1998; appeal bond executed November 17, 1998), the propriety of the NLRC’s remand, and whether petitioners’ Supreme Court filing complied with Rule 45’s 15-day rule after notice of the Court of Appeals’ denial of motion for reconsideration (petitioners received notice November 9, 2001; new counsel entered November 23, 2001; petitioners sought an extension on June 16, 2002).
Issues:
- Did the NLRC acquire jurisdiction over petitioners’ appeal despite the appeal bond being posted seven days after the ten-day reglementary period?
- Was the NLRC’s remand of the case to the Labor Arbiter for further proceedings proper when petitioners tendered evidence on appeal that they had not presented before the Arbiter?
- Did the Court of Appeals commit grave abuse of discretion in giving due course to the petition for certiorari under Rule 65 and annulling the NLRC resolutions and reinstating the Labor Arbiter’s decision?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)