G.R. No. 93023 - Achacoso vs. Macaraig

Petitioner, employed as a machine operator at San Miguel Corporation Metal Closure and Lithography Plant, was engaged in the manufacturing of printed metal caps and crowns for beer, beverage, and pharmaceutical products.
At the Canlubang Plant, an altercation occurred on the afternoon of September 23, 2002, involving petitioner and his co-employee, Renato Regala.

Regala reportedly went to the plant to distribute anti-union materials which petitioner contended were libelous and defamatory.
In his capacity as union steward, petitioner confronted Regala, and the confrontation escalated into a charged verbal exchange.

During the heated exchange, petitioner elbowed Regala, striking him in the face and causing him to lose balance and fall.
As a consequence, Regala lodged a complaint with the Human Resources Department of San Miguel Corporation.

The company conducted an administrative investigation, affording both parties the opportunity to explain their side. Notably, petitioner opted to remain silent and did not respond to the charges.
On January 29, 2003, the designated company investigator submitted a report and recommendation finding petitioner guilty of causing willful injury to another employee, an infraction of company rules and regulations.
On February 7, 2003, petitioner was served a termination letter based on the investigator’s findings and recommendation.

Petitioner subsequently filed a complaint for illegal dismissal against the respondent with the Labor Arbiter.
The Labor Arbiter rendered a Decision on January 4, 2005, dismissing the complaint for lack of merit.

Dissatisfied with the Labor Arbiter’s Decision, petitioner filed an appeal with the National Labor Relations Commission (NLRC).
The NLRC affirmed the Labor Arbiter’s Decision in its April 30, 2008 ruling and later denied petitioner’s motion for reconsideration on October 31, 2008.

Petitioner sought to assail the NLRC Decision by initiating a special civil action for certiorari before the CA.
On February 9, 2009, petitioner filed a Motion for Extension of Time to File the Petition for Certiorari, contending that his former counsel’s unavailability and the subsequent hiring of new counsel contributed to the delay.

The CA, on February 13, 2009, issued a Resolution denying the Motion for Extension of Time, citing the non-extendible nature of the 60-day period for filing a petition for certiorari as mandated by the amended provisions of Section 4, Rule 65 of the Rules of Court.
On March 9, 2009, the CA further ruled that petitioner’s certiorari petition was filed out of time, thereby declaring the NLRC Decision final and executory.

Petitioner, in reaction to the CA’s ruling on the timeliness of his petition, filed a Motion for Reconsideration.
On July 15, 2009, the CA issued its final Resolution denying the Motion for Reconsideration on the ground of lack of merit.

That the CA gravely abused its discretion by failing to decide the case on its merits.
That the CA failed to review the substantial facts and applicable laws.
That petitioner was unlawfully dismissed, thus entitling him to reinstatement; full backwages and other benefits; as well as damages and attorney’s fees.

Whether the CA gravely abused its discretion by not deciding this case on its merits, particularly by dismissing petitioner’s certiorari petition based solely on the timeliness issue.
Whether the CA failed to scrutinize and apply the substantial facts and applicable laws pertinent to the case, including the grounds for dismissal.
Whether petitioner was unlawfully dismissed, which, if proven on the merits, would entitle him to reinstatement with full backwages, benefits, damages, and attorney’s fees.