G.R. No. 144638 - Matagumpay Maritime Co., Inc. vs. Dela Cruz

Matagumpay Maritime Co., Inc. is a manning agency for shipping vessels, notably for Yeh Shipping Co., Ltd.
Benedict C. Dela Cruz was employed by petitioner as a seaman on the vessel M/V Kirillis Barbara with a monthly salary of US $440.00.

Employment commenced on May 10, 1993, for a period of one year ending on May 10, 1994.
On July 15, 1993, just two months after his employment began, respondent was diagnosed with arthritis and repatriated to the Philippines for treatment at the Seaman’s Hospital.
Later, respondent suffered severe chest pains, prompting his confinement at the Manila Medical Center where he was diagnosed with rheumatic heart disease.
On October 15, 1993, his attending physician issued a certificate declaring him “fit to work,” and he resumed work but was advised to report periodically.
Respondent also attended a one-week radar observation course during this period.
In January 1994, while visiting a co-employee aboard petitioner’s M/V Cedar Forest, he learned from Noimi Zabala that the company refused to re-employ him because of his medical condition.
On June 14, 1994, another medical certificate was issued, confirming his ailments as “work-oriented arthritis, acute A knee and rheumatic heart disease.”

Respondent initially filed an application with the Overseas Workers Welfare Administration (OWWA) for permanent disability benefits, which he later withdrew.
On October 24, 1997, respondent filed a complaint with the Labor Arbiter alleging illegal dismissal and non-payment of wages and disability benefits (NCR OFW Case No. 97-10-4347).
The Labor Arbiter rendered a decision on July 7, 1999, dismissing the complaint but awarding respondent US $440.00 as financial assistance.
On appeal, the National Labor Relations Commission (NLRC) issued a Resolution on November 17, 1999, modifying the Arbiter’s decision by also granting respondent disability benefits amounting to US $10,075.00, with corresponding legal interest for delayed payments.
Petitioners filed a motion for reconsideration before the NLRC, which was denied in a Resolution dated April 24, 2000.

On July 10, 2000, petitioners filed a petition for certiorari with the Court of Appeals seeking temporary relief, contending that the NLRC resolutions were tainted by grave abuse of discretion.
In a Resolution dated July 18, 2000, the Court of Appeals dismissed the petition on the ground that it was filed late by ten (10) days, as the petition should have been filed within a 50-day period following the receipt of the NLRC’s denial.
Petitioners then filed a motion for reconsideration with the Court of Appeals, which was again denied on August 30, 2000.
The central contention in the instant petition was that the dismissal of the petition for certiorari on timeliness grounds was erroneous.

Whether the petition for certiorari filed by petitioners was filed within the prescribed fifty (50) day period, as required under Section 4, Rule 65 of the 1997 Rules of Civil Procedure.
Whether the Court of Appeals erred in dismissing the petition on the ground of procedural delay, specifically a delay of ten (10) days beyond the allowed period.
Whether the strict application of the 60-day period (with interruption by a timely filed motion for reconsideration) for filing a petition for certiorari should prevail in this instance.