G.R. No. 194575 - Gabriel vs. Petron Corporation

Petron Corporation hired Angelito N. Gabriel as a Maintenance Technician in May 1987.
By virtue of his years of service and continued education, Gabriel eventually ascended to the position of Quality Management Systems (QMS) Coordinator on 18 October 2004.
Despite assuming additional duties, Gabriel received neither a salary increase nor additional benefits, an omission later linked to subsequent company actions.

The trigger event was a complaint filed by Ms. Charina Quiwa, goddaughter of Alfred A. Trio, General Manager of the Refining Division in Limay, alleging that Gabriel had fabricated emails to falsely implicate an extramarital affair.
Following the complaint, Gabriel was issued a notice to explain his side; however, the notice controversially failed to include the original letter by Quiwa.
Gabriel denied any harassment of Quiwa or her family, maintaining that he had resolved the misunderstanding in confidence.
Subsequent actions and investigations by company management interpreted his behavior as violations of internal rules, culminating in a series of harassment acts against him.

Gabriel was charged with multiple offenses, including dishonesty, misconduct, misbehavior, and violation of the “netiquette” policy.
Specific allegations included:

Proposing training services for another refinery using Petron’s proprietary courses through his own firm, Gabriel Consultancy Services.
Unauthorized use of company equipment and resources to reproduce 1,603 pages of proprietary materials.

Gabriel was required to justify these charges, and despite providing explanations—including stating that he had been placed in an unbearable and humiliating situation—disciplinary measures continued.
His failure to attend subsequent hearings resulted in an additional notice for absence without official leave.
On 12 May 2005, management imposed a ten (10) day suspension.

On 19 April 2007, after the submission of position papers by both parties, a labor arbiter rendered a decision in favor of Gabriel.

The labor arbiter determined that the QMS Coordinator position was supervisory, confirming that Gabriel had, in fact, been promoted.
The arbiter noted that Ms. Quiwa’s complaint, though initially appearing serious, was not connected with Gabriel’s work and did not affect his performance.
Other charges against Gabriel were deemed acts of harassment or collateral consequences of the original complaint.

The labor arbiter awarded Gabriel full back wages, separation pay, moral and exemplary damages, and attorney’s fees.
On 27 April 2009, the NLRC reversed the labor arbiter’s judgment by dismissing the complaint against Petron based on findings that:

Gabriel’s appointment was a lateral transfer (no increase in rank/salary).
His reassignment did not constitute a demotion.
The assignment was intended more to allow him to defend himself rather than to punish him.
Insufficient evidence existed to substantiate the harassment allegations.

Following the NLRC decision, Gabriel sought recourse with the CA.
His counsel’s motion for reconsideration was submitted after the denial of a motion for extension to file a petition for certiorari.

Gabriel’s counsel had filed the motion for extension on 10 July 2010 due to time and distance constraints, specifically his need to secure authentication from the Philippine Consular Office in Australia.
On 21 July 2010, the CA, citing Section 4, Rule 65 of the Rules of Civil Procedure and precedent from Laguna Metts Corporation v. CA, denied the motion for extension.

Gabriel subsequently filed a motion for reconsideration of the CA ruling, contending that exceptional circumstances justified a relaxation of the prescribed rules.
The CA maintained that his motion lacked substantial and meritorious grounds to reverse its earlier denial.

Whether the CA erred in denying Gabriel’s motion for extension to file a petition for certiorari, taking into account the strict time limits imposed by Section 4, Rule 65.
Whether the exceptional circumstances, such as the time and distance constraints faced by Gabriel in Australia, were sufficient to warrant a relaxation of the procedural requirements.

Whether the NLRC acted with grave abuse of discretion or in excess of its jurisdiction when it reversed the favorable decision of the labor arbiter.
Whether the CA was correct to dismiss issues raised regarding the alleged constructive dismissal and other charges against Gabriel on procedural and jurisdictional grounds.

Whether the petition for certiorari should be limited solely to issues of jurisdiction and grave abuse of discretion or whether the merits of the underlying labor case should also be scrutinized.
How the doctrine on the hierarchy of courts and the finality of NLRC decisions under Article 229 of the Labor Code are to be applied in assessing the CA and NLRC decisions.