Case Summary (G.R. No. L-43800)
Applicable Law
The pertinent legislation applicable to the case includes the 1987 Philippine Constitution and the 1997 Rules of Civil Procedure.
Background of the Case
In 1991, SMC initiated a viability study and subsequently executed a modernization program that incorporated new high-speed machinery. This change resulted in the cessation of operations for relevant production lines and declared redundancies among the workforce. On February 13, 1992, SMC formally notified the Department of Labor and Employment (DOLE) about the impending termination of certain employees. The affected employees were offered severance packages including substantial financial compensation and assistance in job placement which they accepted, executing quitclaims.
Complaints Filed
Two years post-termination, the employees filed complaints against SMC with the Labor Arbiter, arguing that the modernization program was a façade to effectuate an illegal mass layoff. They sought the legal declaration of their separation as illegal, with claims for back wages and other benefits. The Labor Arbiter dismissed the complaints on November 25, 1996.
Appeal to the NLRC
The employees then appealed to the National Labor Relations Commission (NLRC), which upheld the Labor Arbiter’s decision, confirming that the modernization program was a valid reason for employment termination. The Commission’s ruling was documented and the petitioners filed a special civil action for certiorari before the Court of Appeals, which ultimately dismissed their petition.
Court of Appeals’ Dismissal
The dismissal by the Court of Appeals was based on procedural non-compliance—the absence of a certified true copy of the NLRC's resolution and the late filing of the appeal by seven days. This non-compliance with procedural requirements as outlined in Section 3, Rule 46 of the 1997 Rules of Civil Procedure provided sufficient grounds for dismissal.
Petitioners’ Justification for Non-compliance
The petitioners’ counsel attempted to justify the failure to attach the requisite certified true copy by citing challenges in organizing voluminous documents. However, the counsel's inability to comply with procedural requirements was deemed insufficient to warrant reconsideration.
Legal Prec
...continue readingCase Syllabus (G.R. No. L-43800)
Case Background
- The case involves 120 petitioners who were former employees of San Miguel Corporation (SMC) at its Mandaue Brewery Plant.
- The petitioners filed for a review seeking to reverse the Resolutions of the Court of Appeals dated January 25, 2000, and March 7, 2000, which dismissed their petition for review on certiorari.
- The dismissal was based on two main grounds: (1) failure to attach a certified true copy of the assailed Resolution of the National Labor Relations Commission (NLRC) in NLRC Case No. V-0099-97, and (2) the petition was filed beyond the reglementary period.
Modernization Program and Redundancy
- In 1991, SMC conducted a viability study and implemented a modernization program that involved the installation of high-speed machines in the bottling lines of the Mandaue plant.
- This modernization led to the cessation of operations on main lines (1, 2, 3, 4, and 5), resulting in the declaration of several employee functions as redundant.
- On February 13, 1992, SMC notified the Department of Labor and Employment (DOLE) about the termination of services for certain employees due to redundancy, providing them with separation packages.
Separation and Quitclaims
- Affected employees received a separation pay of 175% of their monthly salaries for each year of service, along with three years of free hospitalization and support for livelihood programs.
- The em