Case Summary (G.R. No. 142405)

Petition for Review and Dismissal by the Court of Appeals

The petitioners, consisting of 120 former employees of San Miguel Corporation (SMC), sought to reverse the Court of Appeals' resolutions that dismissed their petition for review. The dismissal was based on two primary grounds: the failure to attach a certified true copy of the National Labor Relations Commission (NLRC) resolution being contested and the late filing of the petition beyond the reglementary period.

• 120 former employees of SMC filed a petition for review.
• The Court of Appeals dismissed the petition for two reasons:
  • Lack of a certified true copy of the NLRC resolution.
  • Filing the petition seven days late.

Background of Employment and Termination

The petitioners were employed at SMC's Mandaue Brewery Plant and were affected by a modernization program initiated by the company in 1991. This program involved the installation of high-speed machines, leading to the redundancy of several employee functions. SMC notified the Department of Labor and Employment (DOLE) and the affected employees about the termination of their services, offering separation pay and other benefits.

• SMC conducted a modernization program in 1991.
• High-speed machines were installed, rendering several employee functions redundant.
• Employees were notified of their termination and offered separation pay and benefits.

Legal Complaints and Labor Arbiter's Decision

Two years after their termination, the employees filed complaints with the Labor Arbiter, alleging illegal mass lay-offs and seeking backwages and other benefits. The Labor Arbiter dismissed their complaints, a decision that was later affirmed by the NLRC, leading the petitioners to seek recourse through the Court of Appeals.

• Employees filed complaints alleging illegal mass lay-offs.
• The Labor Arbiter dismissed the complaints.
• The NLRC affirmed the dismissal, prompting the petitioners to appeal to the Court of Appeals.

Grounds for Dismissal by the Court of Appeals

The Court of Appeals dismissed the petition based on procedural grounds, specifically the failure to comply with the requirements set forth in the 1997 Rules of Civil Procedure. The petitioners did not attach the necessary certified true copy of the NLRC resolution and acknowledged the seven-day delay in filing their petition.

• The Court of Appeals cited non-compliance with procedural requirements.
• Petitioners failed to attach a certified true copy of the NLRC resolution.
• Petitioners admitted to a seven-day delay in filing.

Counsel's Justification and Court's Response

The petitioners' counsel attempted to justify the omission of the required document by citing the challenges of handling voluminous documents. However, the Court found this explanation insufficient, emphasizing the importance of diligence in legal practice and the binding nature of the quitclaims signed by the employees.

• Coun...continue reading

Case Syllabus (G.R. No. 142405)

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 liv...continue reading