G.R. No. 199617 - Torrecampo vs. National Labor Relations Commission

The petitioners—Rey Torrecampo, Jovita V. Calma, Winthrop Mark N. Barba, and Leo Q. Tapnio—filed a Petition for Review on Certiorari before the Supreme Court.
The petitioners sought to reverse and set aside the Resolutions of the Court of Appeals (CA) dated 12 July 2011 and 6 December 2011, which dismissed their Petition for Certiorari on the ground that it was filed out of time.
The impugned CA resolutions upheld the finality and executory nature of the National Labor Relations Commission (NLRC) Decision dated 5 January 2011 and its Resolution dated 7 March 2011.

The CA issued a resolution on 12 July 2011 dismissing the petition for certiorari because it was not perfected within the 60-day reglementary period prescribed under the Revised Rules of Court.
In its resolution, the CA noted that petitioners not only filed late but also allegedly misrepresented the date of receipt of the NLRC resolution, claiming receipt on 27 March 2011 rather than the actual date of 21 March 2011.
The CA further observed that petitioners attempted to shift blame to the housemaid of their counsel on record for their delay, asserting that erroneous information led them to believe the NLRC resolution was received later than it actually was.
A subsequent motion for reconsideration was filed by the petitioners which was denied on 6 December 2011 by the appellate court.

The factual controversy centered on whether the NLRC Resolution was indeed received on 21 March 2011, thereby triggering the start of the 60-day period within which the petition for certiorari should have been filed.
Evidence confirmed that petitioners received the NLRC Resolution on 21 March 2011.
Since the 60-day period extended until 20 May 2011, the petitioners’ filing on 25 May 2011 was five days beyond the allowable reglementary period.

Petitioners contended that the strict application of the 60-day rule was unjust, arguing that their delay was due primarily to the negligence of their former counsel who deserted the case without proper notification.
They also emphasized that reliance on the declaration of the housemaid was made in good faith, and that an interpretation of the rules should be liberally construed to allow the merits of the case to be considered rather than dismissing it on a technicality.

Whether the Court of Appeals erred in strictly applying the 60-day reglementary period under the Revised Rules of Court in dismissing the petition for certiorari.
Whether external factors, such as the negligence of counsel and misinformation by a housemaid, constitute sufficient grounds to relax or extend the statutory time limit for filing a petition for certiorari.
Whether the substantive merits of the case should be examined despite the procedural lapse in filing the appeal within the prescribed period.