Case Summary (G.R. No. 139940)
Applicable Law
The proceedings are governed by the 1987 Philippine Constitution, the Labor Code of the Philippines, and the Rules of Court, specifically the 1997 Rules of Civil Procedure, which structures the framework for labor disputes and procedural matters relate to the petitions in question.
Procedural History
The petition for certiorari critiques the resolutions of the Court of Appeals dated April 13, 1999, and September 3, 1999, which dismissed the petitioners' motion for certiorari as it was filed six days beyond the prescribed period under Section 4, Rule 65. The petitioners argued for substantial justice and a liberal interpretation of the rules to allow the issues to be decided on their merits rather than procedural technicalities.
Timeline of Events
The petitioners filed a timely motion for reconsideration following the Court of Appeals’ resolution, which was received on September 13, 1999. They timely moved for a 30-day extension of the period to file their certiorari petition, which the Supreme Court approved. A formal petition for certiorari was subsequently filed on October 28, 1999.
Retroactive Application of Amendments
The Supreme Court acknowledged that although the appellate court's resolutions were issued prior to the new amendments to Section 4 of Rule 65, the changes were deemed applicable retroactively. This ruling aligns with prior jurisprudence permitting retroactive application of rule amendments as long as they do not adversely affect vested rights. Thus, the Supreme Court opted to resolve the petition on its merits rather than remanding it back to the appellate court.
Primary Issues Addressed
The Union filed a Notice of Strike alleging the University committed Unfair Labor Practices (ULPs), including interference in union activities, disregard for collective bargaining agreement (CBA) stipulations, and improper contracting out of work. Additionally, an audit petition concerning union funds was filed against Union officers by some of the Union members, which escalated tensions and gave rise to further disputes.
Administrative Processes
The NLRC took cognizance of the Union's grievances and established a timeline of hearings attempted to resolve the disputes, concluding with a resolution on October 12, 1998. The NLRC ultimately dismissed the Union's complaints against the University regarding ULPs, ruling that the Union had not sufficiently proven their allegations.
Findings of the NLRC
The NLRC’s decision concluded that there was no interference by the University in union activities, finding that the initiative for the audit came from the Union members, not the University. The claims of union busting were similarly dismissed due to lack of sufficient evidence that the University had violated any provisions set forth in the CBA.
Consequences of the Strike
Regarding the strike that occurred between August 5-7, 1998, the NLRC ruled it illegal based on the violation of a Return-to-Work Order by the DOLE Secretary. As a result, all striking employees lost their employment status. The NLRC justified the University’s actions during the strike, deeming them lawful based on the explicit stipulations of the Labor Code.
Certification of Decisions
The Supreme Court recognized the rulings from the NLRC, ultimately aff
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Case Background
- The case involves a petition for certiorari filed by the Arellano University Employees and Workers Union and several of its members against the Court of Appeals and Arellano University, Inc.
- The petition challenges the Court of Appeals' resolutions which dismissed the petitioners' earlier petition for certiorari due to late filing, specifically six days beyond the reglementary period.
Procedural History
- The petitioners received the Court of Appeals' Resolution denying their motion for reconsideration on September 13, 1999.
- On September 27, 1999, the petitioners sought a 30-day extension to file their certiorari petition, which was granted by the Supreme Court.
- The petition was eventually filed on October 28, 1999.
- The Court clarified that the petition could not be treated merely as a substitute for a lost appeal and would be considered under Rule 45 for review.
Amendments to Rule 65
- The relevant procedural rules, particularly Section 4 of Rule 65 of the 1997 Rules of Civil Procedure, underwent amendments.
- The amendment allowed for a 60-day period to file a petition following the denial of a motion for reconsideration or new trial.
- The Supreme Court determined that the amended rule should be applied retroactively to the petitioners’ case.
Facts of the Case
- The Union filed a Notice of Strike against Arellano University on December 12, 1997,