G.R. No. 108871 - People vs. Ballabare

Respondents filed a complaint for illegal dismissal and monetary claims (service incentive leave, 13th month pay, and night shift differential) against petitioners, namely FILSYSTS, Inc. and Felipe A. Cruz, Jr., before the National Labor Relations Commission (NLRC).
The complaint was assigned to Labor Arbiter Donato G. Quinto, Jr., who ordered the submission of position papers from both parties.
While respondents complied with the order, petitioners failed to file their position paper despite several warnings and multiple time extensions; their inaction was later construed as a waiver of their right to present evidence at that stage.

The Labor Arbiter ruled in favor of the respondents on the merits by sustaining their claim of illegal dismissal due to petitioners’ failure to adduce contrary evidence.
The Arbiter also granted respondents’ monetary claims, ordering the reinstatement of respondents.

Petitioners appealed the Arbiter’s decision before the NLRC, and for the first time, they submitted evidence allegedly showing that respondents were project employees dismissed due to the discontinuation of the Jaka Tower I project.
Respondents contested the NLRC’s jurisdiction on the appeal, arguing that petitioners filed their appeal bond 7 days beyond the ten (10)-day reglementary period established by law.
Despite this contention, the NLRC assumed jurisdiction over the appeal and, based on the newly submitted evidence, remanded the case back to the Labor Arbiter for further proceedings.

Respondents filed a petition for certiorari with the Court of Appeals, challenging the NLRC’s jurisdiction and the procedural handling of the appeal and the subsequent submission of evidence by petitioners.
The Court of Appeals ruled that the NLRC was without jurisdiction over petitioners’ appeal because the appeal bond was filed late—beyond the ten (10)-day reglementary period—and reinstated the Labor Arbiter’s decision.
Petitioners’ motion for reconsideration before the Court of Appeals was denied, prompting the present petition raising several legal issues.

Whether the appellate court erred in finding and ruling that the NLRC lost jurisdiction over the appeal due to the late submission of the appeal bond (filed 7 days beyond the ten-day deadline).

Whether it was proper for the petitioners to introduce evidence on the issue of illegal dismissal at the NLRC stage, despite having ample opportunity to present it before the Labor Arbiter.

Whether the remand of the case to the Labor Arbiter—due to conflicting claims raised during the appeal—constituted a grave abuse of discretion as alleged by petitioners.
Whether the Court of Appeals committed grave abuse of discretion by giving due course to the petition for certiorari under Rule 65, annulling the NLRC resolutions, and reinstating the Labor Arbiter’s decision awarding reinstatement and monetary benefits to the respondents.

Whether the petition for certiorari should be allowed given that the decision of the Court of Appeals had already become final and executory, and whether the petition was filed within the fifteen-day period provided under Rule 45 of the Rules of Court.