G.R. No. 229326 - Bismonte vs. Golden Sunset Resort and Spa

Petitioners, consisting of eight individuals, filed a petition for review on certiorari against respondents Golden Sunset Resort and Spa and Ricardo "Ricky" Reyes.
The petition challenges the Court of Appeals' Decision and Resolution that annulled the National Labor Relations Commission's (NLRC) ruling, which had favored the petitioners regarding their complaints of illegal dismissal and non-payment of benefits.
The NLRC had previously ruled in favor of the petitioners, recognizing them as regular employees entitled to various monetary claims.

Petitioners claimed they were hired as resort staff in various capacities, including housekeepers and waiters.
Three petitioners alleged they were dismissed without just cause and due process.
Five petitioners contended they were constructively dismissed due to a significant reduction in their work schedule, leading to decreased income.
They also accused respondents of failing to pay entitled benefits such as holiday pay, overtime pay, and service incentive leave pay.

Respondents argued that petitioners were seasonal employees, not regular employees, and that their work schedules were adjusted based on seasonal demand.
They claimed that during lean seasons, they reduced workdays or allowed employees to seek other employment.
Respondents maintained that they did not exercise control over the petitioners' work, likening their relationship to independent contractorship.

The Labor Arbiter (LA) dismissed the complaints, concluding that no employer-employee relationship existed due to the lack of control over the petitioners' work.
Petitioners appealed the LA's decision to the NLRC.

The NLRC overturned the LA's decision, recognizing petitioners as regular employees and ordering respondents to pay them a total of P1,076,833.50 for various unpaid benefits.
The NLRC found that petitioners had been issued company identification cards and that their work was essential to the business.
However, the NLRC ruled that three petitioners did not prove actual dismissal, and the reduction in workdays for the other five did not constitute constructive dismissal.

The Court of Appeals annulled the NLRC's ruling, reinstating the LA's decision based on the argument that petitioners failed to file their appeal on time.
The CA noted that the appeal was received by the NLRC after the ten-day period allowed for filing.
The CA criticized the Public Attorney's Office (PAO) for not filing the appeal in person, given its proximity to the NLRC.

The primary issue was whether the CA correctly determined that petitioners failed to comply with filing and service requirements for their appeal to the NLRC and whether the appeal was filed out of time.

The Supreme Court found merit in the petition, stating that the NLRC Rules of Procedure allow for the application of the Rules of Court regarding filing and service of pleadings.
The Court emphasized that personal filing is preferred but exceptions exist, particularly when substantial justice is at stake.
The Court noted that the petitioners' appeal was filed via registered mail on time, as evidenced by the post office stamp and certification from the postmaster.

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