Case Summary (G.R. No. 202086)
Antecedents of the Case
In September 2012, the NCMB's voluntary arbitrator ruled in favor of the employees' entitlement to salary adjustments for the years 2010 and 2011, leading DORELCO to pay retirement benefits to employees who did not sign quitclaims. However, in 2017, the voluntary arbitrator decided that employees who had executed quitclaims upon retirement, including Epigenio S. Lumbre and others, were not entitled to the salary increases, prompting the Union to seek reconsideration of this decision. The motion for reconsideration was subsequently denied, leading to an appeal being filed with the Court of Appeals (CA) in December 2017.
Legal Issues Raised
The primary legal issue pertains to the timeliness of the appeal lodged by the Union against the decision of the voluntary arbitrator. According to the CA, appeals must be filed within ten calendar days from receipt of the arbitrator's decision, which the Union failed to comply with, resulting in a dismissal of their petition for being late. The Union argued for a fifteen-day period in accordance with Rule 43 of the Rules of Court, asserting the right to appeal the denial of their motion for reconsideration.
Court of Appeals' Resolution
On March 8, 2018, the CA dismissed the Union's petition on the grounds that the appeal was filed beyond the ten-day limit specified under Article 276 of the Labor Code. The CA emphasized that the decision of the voluntary arbitrator becomes final and executory if not appealed within the specified timeframe, and that a motion for reconsideration is excluded based on existing guidelines articulated in Department Order No. 40, series of 2003.
Argument by the Union
In its motion for reconsideration of the CA's dismissal, the Union invoked a past Supreme Court ruling, Teng v. Pahagac, which suggested that parties may seek reconsideration within the 10-day period as a necessary measure before proceeding with an appeal. However, this plea was again denied by the CA on May 21, 2018, which held firm to the position that the appeal had not been filed timely as mandated.
Supreme Court Ruling
In ruling on the case, the Supreme Court clarified disparities regarding the appeal periods. The Court concluded that under Article 276 of the Labor Code, the 10-day period serves to allow parties to file a motion for reconsideration, and only upon resolving such motion can the aggrieved party file a subsequent appeal within a 15-day timeframe as per Rule 43. This interpretation aligns with the principle of exhausting administrat
...continue readingCase Syllabus (G.R. No. 202086)
Overview
- The case revolves around the timeliness of an appeal from a voluntary arbitrator's decision concerning salary adjustments for employees under a collective bargaining agreement.
- The Supreme Court deliberated on the procedural intricacies of appealing such decisions and the statutory timelines involved.
Antecedents
- In 2012, the DORELCO Employees Union-ALU TUCP (Union) and Don Orestes Romualdez Electric Cooperative, Inc. (Company) submitted a dispute regarding salary adjustments for rank-and-file employees to the National Conciliation and Mediation Board (NCMB) for arbitration.
- Several employees, including Gregorio Pingol and others, opted not to sign quitclaims to receive retirement benefits, preferring to await the arbitration outcome, while others executed quitclaims.
- On September 25, 2012, the NCMB voluntary arbitrator ruled in favor of the employees, mandating salary increases for 2010 and 2011.
- The Company subsequently paid the employees (Pingol, et al.) their retirement benefits, including salary differentials.
- In 2017, the Union sought arbitration again regarding salary adjustments for the employees who had executed quitclaims (Lumbre, et al.), which resulted in a ruling that they were not entitled to salary increases due to their quitclaims.
- The Union's motion for reconsideration was denied, and the Union filed a Petition for Review with the Court of