Case Summary (G.R. No. 188839)
Factual Background
Cesar Naguit was employed as a machine operator at San Miguel Corporation's Metal Closure and Lithography Plant. On September 23, 2002, an altercation occurred between him and fellow employee Renato Regala while Regala was allegedly distributing anti-union materials. Naguit confronted Regala, resulting in a physical altercation where Naguit elbowed Regala in the face, causing Regala to fall. Following this incident, Regala filed a complaint with the corporation's Human Resources Department, prompting an administrative investigation. Naguit chose not to defend himself during this investigation, which led to the finding of his guilt for willful injury, in violation of company rules.
Administrative Actions and Dismissal
Based on the investigator’s report submitted on January 29, 2003, San Miguel Corporation terminated Naguit's employment on February 7, 2003, citing his actions as grounds for dismissal. He subsequently filed a complaint for illegal dismissal. The Labor Arbiter ruled in favor of the respondent corporation on January 4, 2005, dismissing Naguit’s complaint for lack of merit. This decision was affirmed by the National Labor Relations Commission (NLRC) on April 30, 2008. A motion for reconsideration was also denied by the NLRC.
Procedural History
Naguit sought to appeal the NLRC’s decision through a petition for certiorari with the Court of Appeals (CA) but failed to submit it on time. He requested an extension of time on February 9, 2009, citing his former counsel's inadequacy and his recent appointment of new counsel who needed time to review the case. However, the CA denied this motion on February 13, 2009, emphasizing that the 60-day period for filing a certiorari petition is non-extendible under Rule 65 of the Rules of Court. The CA further noted that the NLRC's decision was final and executory due to his untimely appeal.
Issues Raised
The principal issues presented in the petition were whether the CA exercised grave abuse of discretion by not deciding the case on the merits, whether the CA overlooked substantial facts and applicable laws, and whether Naguit was unlawfully dismissed, thereby entitled to reinstatement, back wages, damages, and attorney’s fees.
Court’s Ruling
The Court rejected Naguit’s petition, affirming the CA's resolution. First, it held that the CA properly dismissed the petition due to procedural deficiencies. The Court reiterated that strict compliance with procedural rules is necessary, and failure to observe these rules rendered the case jurisdictional, depriving the CA of authority over the case.
The Court held that Naguit's reasons for failing to meet procedural deadlines were insufficient. The assertion that workload or unavailability of counsel justified his late filing was not compelling, as it is the litigant's responsibility to monitor their case. The argument that procedural rules should yield to substantial justice was also dismissed, affirming that procedural rules are integral to an orderly administration of justice.
Substantive Findings
On the substantive matters, the Court reinforced the principle that issues of fact cannot be reviewed in a certiorari petition, instead focusing on whether the NLRC's findings w
...continue readingCase Syllabus (G.R. No. 188839)
Case Background
- The case involves a petition for review on certiorari under Rule 45 of the Rules of Court, filed by Cesar Naguit against San Miguel Corporation.
- The petition challenges the Resolutions of the Court of Appeals (CA) dated February 13, 2009, and July 15, 2009, in CA-G.R. SP No. 107311.
- The February 13, 2009 resolution denied Naguit's Motion for Extension of Time to File Petition for Certiorari, while the July 15, 2009 resolution denied his Motion for Reconsideration.
Employment Context
- Cesar Naguit was employed as a machine operator at San Miguel Corporation's Metal Closure and Lithography Plant, which manufactures printed metal caps and crowns for various products.
- On September 23, 2002, Naguit was involved in an altercation with a fellow employee, Renato Regala, over the distribution of anti-union materials, which Naguit claimed were defamatory.
- The confrontation escalated, resulting in Naguit elbowing Regala, leading to Regala’s complaint to the Human Resources Department.
Administrative Investigation
- An administrative investigation was conducted by the company, where both parties were given the opportunity to present their cases.
- Naguit chose to remain silent and did not address the charges against him.
- The company-designated investigator submitted a report on January 29, 2003, finding Naguit guilty of willful injury to another employee, a violation of company rules.
Termination of Employment
- On February 7, 2003, Naguit was formally notified of his termination based on the investigator's findings.
- In response, Naguit filed a complaint for i