Facts:
Thomasites Center for International Studies (
TCIS) sought review of a May 24, 2012 Resolution of the Court of Appeals (
CA) in CA-G.R. SP No. 124630, which had dismissed outright TCIS’s petition for certiorari from a September 30, 2011 Decision of the National Labor Relations Commission (
NLRC) in NLRC Case Nos. RAB-III-01-8376-05 and RAB-III-01-8401-05. The labor dispute arose from the employment of Ruth N. Rodriguez (
Rodriguez), Arlyn B. Rillera (
Rillera), and Irene P. Padrigon (
Padrigon), all graduates of the University of the Philippines holding teaching licenses, who were hired on July 29, 2004 by Dr. Jae Won Park and Dr. Cheol Je Cho (
Dr. Cho), Korean nationals and President and Academic Dean of TCIS, respectively. The respondents were tasked to develop academic programs, design curricula, create materials for the school’s website, recruit staff, draft documents for the Technical Education and Skills Development Authority accreditation, help supervise the construction of the school building in Subic Bay Metropolitan Authority, and draft school rules and student and faculty handbooks. Although no written contracts were executed, the respondents were promised a monthly salary of
P25,000.00 plus shares of stock. After classes opened on December 20, 2004 at the Crown Peak Hotel in Subic Bay, disagreements emerged regarding salaries between the respondents and American teachers. At a meeting called by Dr. Cho on January 7, 2005, the American teachers threatened to resign unless the respondents were terminated; that same afternoon, the respondents received letters of termination effective January 8, 2005, signed by Dr. Cho, citing restructuring and consequent evaluation of staffing requirements. Rodriguez and Rillera filed NLRC Case No. RAB-III-01-8376-05 on January 24, 2005, while Padrigon filed NLRC Case No. RAB-III-01-8401-05, both for
illegal dismissal and money claims against TCIS and Dr. Cho. TCIS and Dr. Cho were served summons through Dr. Cho and were given ten days to submit position papers; they did not file position papers but were represented by counsel at hearings on February 15, 2005, March 15, 2005, and April 19, 2005. On May 8, 2006, the Labor Arbiter rendered a Decision finding the respondents
illegally dismissed and ordering reinstatement with full backwages totaling
P1,125,000.00 plus
10% attorney’s fees, which Dr. Cho received on June 21, 2006. After the complainants moved for issuance of a writ of execution on August 11, 2006, a pre-execution conference was held on September 22, 2006 where Atty. Joy P. Bayona appeared as counsel for TCIS and Dr. Cho. Hearings followed on October 2, 2006, October 23, 2006, November 24, 2006, and December 15, 2006; at the December 18, 2006 hearing, the law firm of Andres Marcelo Pedernal Guerrero and Paras entered its appearance as counsel for TCIS and filed a
petition for relief from judgment. On January 30, 2007, the Labor Arbiter directed issuance of a writ of execution and merely noted the petition for relief due to wrong venue and lack of jurisdiction and because it was a prohibited pleading. TCIS then re-filed its petition for relief on February 19, 2007 in the NLRC, praying for a Temporary Restraining Order and/or writ of preliminary injunction, arguing that the Labor Arbiter did not acquire jurisdiction because summons and notices were directed to Dr. Cho who allegedly did not represent TCIS, that Atty. Bayona’s appearance was signed only by Dr. Cho in his capacity as respondent academic dean of TCIS, and that TCIS did not receive notice of the proceedings and was deprived of due process because it was denied the chance to file position papers. TCIS also claimed that a shutdown and irreparable damage would result unless execution was enjoined, while offering to post a bond. The NLRC denied TCIS’s petition on September 30, 2011, holding that it had other adequate remedies such as motion for new trial or appeal, that TCIS failed to show due fraud, accident, mistake, or excusable negligence, and that petition for relief could not be used to revive an appeal lost through negligence. On certiorari, the CA dismissed TCIS’s petition outright on May 24, 2012 due to failure to indicate material dates showing timeliness and due to incomplete attachments to support the petition; the CA further denied reconsideration on September 26, 2012. In its Supreme Court review, TCIS maintained that the NLRC erred in rigidly applying procedural requirements, in finding the summons valid, and in concluding that the respondents were illegally dismissed.
Issues:
Whether TCIS was entitled to relief from judgment and to the issuance of injunctive relief to prevent execution of the Labor Arbiter’s Decision, notwithstanding TCIS’s claims of lack of jurisdiction and alleged deprivation of due process.
Ruling:
Ratio:
Doctrine: