Case Summary (G.R. No. 156367)
Factual Background
In September 1993, Neal H. Cruz was employed by Chronicle Securities Corporation as the publicist and editor in chief of the Manila Chronicle, receiving a monthly salary of ₱60,000. Cruz left his previous job and significantly contributed to improving the publication's financial condition through various initiatives. However, he was terminated following the publication of a controversial article in July 1994, prompting him to file a complaint for illegal dismissal.
Labor Arbiter's Decision
On January 2, 1997, Labor Arbiter Ariel C. Santos ruled in favor of Cruz, finding his dismissal illegal. The decision mandated reinstatement, awarded ₱10 million in moral damages, ₱5 million in exemplary damages, and other benefits, including ownership of the vehicle given as part of his compensation package. This ruling was appealed by the petitioners to the NLRC.
NLRC and Court of Appeals' Rulings
The NLRC affirmed the Labor Arbiter's decision but reduced the moral and exemplary damages significantly. Petitioners sought reconsideration, which was denied. Their subsequent petition for certiorari to the Court of Appeals was also dismissed, affirming the NLRC's decision and findings.
Petitioners’ Arguments
Petitioners contended that the delay in appealing the NLRC’s ruling was due to extraordinary circumstances—a power blackout. They claimed that they intended to file their appeal within the prescribed timeframe but were impeded by events beyond their control. The NLRC ruled their appeal as filed out of time, leading to the finality of the initial awards against them.
Supreme Court's Analysis on Appeal Timeliness
The Supreme Court recognized that the right to appeal is statutory and contingent upon adherence to prescribed timelines. However, it also acknowledged that it may relax these procedural rules to serve the interests of justice. Citing previous rulings, the Court illustrated its willingness to consider circumstances that impede timely filing, asserting that the circumstances faced by the petitioners warranted reviewing the NLRC’s dismissal of their appeal.
Computation of Backwages
On the issue of backwages, the Supreme Court determined that the NLRC and Court of Appeals had erred in their computations. It ruled that backwages should only be awarded until the Manila Chronicle’s closure on January 19, 1998, due to legitimate business reasons that severely impac
...continue readingCase Syllabus (G.R. No. 156367)
Case Overview
- This case involves a petition for review under Rule 45 of the Rules of Court filed by petitioners Chronicle Securities Corporation and Roberto Coyiuto, Jr. against the National Labor Relations Commission (NLRC), Labor Arbiter Ariel C. Santos, and private respondent Neal H. Cruz.
- The petition seeks to set aside the Decision of the Court of Appeals dated November 13, 2002, which denied the Petition for Certiorari and affirmed the February 28, 2001 Order of the NLRC.
Factual Antecedents
- Petitioners hired private respondent Neal H. Cruz in September 1993 as the publicist and editor-in-chief of the Manila Chronicle, offering a monthly salary of P60,000.00 and a brand new car.
- Cruz left his job at Today newspaper to join the Manila Chronicle, implementing changes that improved the newspaper's image, circulation, and advertising revenue.
- In July 1994, Cruz was terminated following his involvement in publishing a controversial article, prompting him to file a complaint for illegal dismissal.
Labor Arbiter's Decision
- On January 2, 1997, Labor Arbiter Ariel C. Santos ruled that Cruz was illegally dismissed and ordered his reinstatement, backwages, moral damages of P10,000,000.00, exemplary damages of P5,000,000.00, and attorney's fees amounting to 10% of the total award.
- Petitioners appealed to the NLRC, which modified the decision by reducing moral damages to P500,000.00 and exemplary damages to P200,000.00.
Court of Appeals Proceedings
- Petitioner