Case Digest (G.R. No. 143789)
Facts:
The case of Systems Factors Corporation and Modesto Dean v. National Labor Relations Commission, Ronaldo Lazaga and Luis C. Singson, G.R. No. 143789, November 27, 2000, Supreme Court Third Division, Gonzaga‑Reyes, J., writing for the Court, concerns whether an administrative amendment to Rule 65's filing period should govern a petition filed before the amendment's effectivity.Systems Factors Corporation (petitioner) employed Ronaldo Lazaga and Luis C. Singson (respondents) as electricians. The respondents filed a complaint for illegal dismissal and various monetary claims. The Labor Arbiter ordered reinstatement and backwages; the National Labor Relations Commission (NLRC) affirmed that decision. Petitioners alleged receipt of the NLRC decision on August 10, 1999 and filed a motion for reconsideration on August 20, 1999. The NLRC denied the motion by resolution received by petitioners on November 25, 1999.
On January 24, 2000 petitioners filed a petition for certiorari under Rule 65 with the Court of Appeals in CA‑G.R. SP No. 56849. The Court of Appeals issued a resolution dated February 15, 2000 dismissing the petition for procedural noncompliance: (1) the petition was filed out of time, and (2) except for the assailed NLRC resolutions, the documents and material portions referred to in the petition were not certified. Petitioners filed a motion for reconsideration; in a June 22, 2000 resolution the Court of Appeals applied Cadayona v. Court of Appeals, G.R. No. 128772, February 3, 2000, accepting petitioners' contention that only the questioned resolution need be certified, but nevertheless denied the motion on the ground that the petition had been filed late.
Petitioners then filed the present petition for certiorari with this Court, invoking A.M. No. 00‑2‑03‑SC—an amendment to Section 4, Rule 65 of the 1997 Rules of Civil Procedure which took effect on September 1, 2000 and provides that when a motion for reconsideration is timely filed the sixty‑day period to seek certiorari shall be counted from notice of the denial of that motion. Petitioners argued the amendment should apply to their case so that the January 24, 2000 ...(Subscriber-Only)
Issues:
- Whether the amendment under A.M. No. 00‑2‑03‑SC to Section 4, Rule 65 (counting the 60‑day period from notice of denial of a timely motion for reconsideration) may be applied to petitions filed before the amendment's effectivity (i.e., whether the amendment operates retroactively to pending, undetermined cases).
- If the amendment applies retroactively, whether the petition for certiorari filed on January 24, 2000...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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