Case Digest (G.R. No. 185220)
Facts:
Laguna Metts Corporation v. Court of Appeals, G.R. No. 185220, July 27, 2009, the Supreme Court First Division, Corona, J., writing for the Court.Private respondents Aries C. Caalam and Geraldine Esguerra (employees alleged to be a machine operator and an inspector) filed a labor complaint against petitioner Laguna Metts Corporation (LMC) for illegal dismissal, regularization, non-payment of service incentive leave, backwages, moral and exemplary damages, and attorney’s fees. The Labor Arbiter ruled in favor of Caalam and Esguerra, finding they had been illegally dismissed. On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter in a decision dated February 21, 2008; the NLRC denied private respondents’ motion for reconsideration in a resolution dated April 30, 2008.
Counsel for private respondents received the NLRC resolution on May 26, 2008. On July 25, 2008 (the last day of the 60-day period for filing a Rule 65 petition), he filed a motion with the Court of Appeals for a 15‑day extension of time to file a petition for certiorari under Rule 65 alleging heavy workload and lack of funds. The Court of Appeals (Seventh Division) granted the motion in a resolution dated August 7, 2008 (docketed CA-G.R. SP No. 104510), giving a non-extendible 15‑day period to file; that resolution was penned by Associate Justice Normandie B. Pizarro with two concurring justices. LMC moved for reconsideration, arguing that the amendments to Rule 65 effected by A.M. No. 07-7-12-SC (effective December 27, 2007) deleted the provision allowing extensions and thus the Court of Appeals no longer had authority to grant extensions. The Court of Appeals denied reconsideration in a resolution dated October 22, 2008, holding it retained discretionary power in exceptional cases.
Aggrieved, LMC filed a petition for certiorari under Rule 65 in the Supreme Court, ...(Subscriber-Only)
Issues:
- Did the Court of Appeals commit grave abuse of discretion by granting a 15‑day extension to file a petition for certiorari after A.M. No. 07-7-12-SC amended Section 4, Rule 65?
- If the Court of Appeals retained discretion to grant extensions, were the reasons offered by private respondents’ counsel—heavy workload and lack of funds—sufficiently compell...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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