G.R. No. 180045 - Government Service Insurance System vs. National Labor Relations Commission

Respondents Dionisio Banlasan, Alfredo T. Tafalla, Telesforo D. Rubia, Rogelio A. Alvarez, Dominador A. Escobal, and Rosauro Panis were employed as security guards by DNL Security Agency.
A service contract was entered into between DNL Security and petitioner Government Service Insurance System (GSIS) on May 1, 1978, under which respondents were assigned to GSIS’s Tacloban City office with a monthly income of P1,400.00.

In July 1989, GSIS voluntarily increased respondents’ monthly salary to P3,000.00.
In February 1993, DNL Security informed respondents of the termination of its service contract with GSIS but instructed them to continue reporting for work, resulting in their continued service without proper compensation until April 20, 1993, when they were terminated and left unpaid.

On June 15, 1995, respondents filed a complaint before the NLRC Regional Arbitration Branch No. VIII in Tacloban City, alleging illegal dismissal, and claiming separation pay, salary differential, 13th month pay, and unpaid wages.
On September 30, 1997, Labor Arbiter Benjamin S. Guimoc rendered a decision:

Found no illegal dismissal based on the contingent nature of security guard employment linked to the service contract.
Awarded separation pay equivalent to one month’s salary per year of service (to be paid solely by DNL Security) considering the prolonged unemployment.
Granted wages for work rendered from February 1993 to April 20, 1993 due to instructions by DNL Security.
Awarded salary differential (for wages below minimum wage) and 13th month pay, with GSIS (the petitioner) held jointly and severally liable as the indirect employer.

DNL Security filed a motion for reconsideration, while GSIS appealed to the NLRC.
The NLRC dismissed both DNL Security’s motion and GSIS’s appeal (the latter for being untimely).
GSIS subsequently filed a petition for certiorari under Rule 65 before the Court of Appeals (CA).

Whether its appeal before the NLRC was timely filed (supported by Registry Receipt No. 34581 dated October 27, 1997, despite a potential one-day discrepancy with the post office stamp).
Whether technicalities regarding timeliness should override substantial justice.
The propriety of holding GSIS jointly and severally liable for claims originally directed against DNL Security.
The award of monetary benefits despite alleged lack of substantive evidence and the claim of processual exemption under its charter.

Whether GSIS’s appeal was filed on time as evidenced by the Registry Receipt and/or the post office stamp, considering a potential one-day discrepancy.
Whether strict application of technical filing rules should prevail over the principles of substantial justice.

Whether GSIS, as an indirect employer under the service contract, can be held jointly and severally liable with DNL Security for respondents’ salary differential, 13th month pay, and unpaid wages.
Whether the extension of respondents’ service for GSIS, even after the termination of contract, implies implied consent and acceptance of financial liability.

Whether the monetary awards (separation pay, wages, salary differential, and 13th month pay) are supported by evidence and proper legal basis.
Whether the punitive character of separation pay precludes imposing such liability on an indirect employer absent evidence of conspiracy in an illegal dismissal.

Whether GSIS’s charter, which provides certain processual exemptions, can be interpreted to exempt the institution from execution of the decision.