Case Summary (G.R. No. 148560)
Background of Proceedings
On December 10, 1962, the CIR’s acting prosecutor filed a complaint on behalf of forty-three employees from La Perla Cigar and Cigarette Factory, alleging unfair labor practices against their employer and its manager. The respondents submitted an answer on January 7, 1963, disputing some allegations and seeking the complaint's dismissal. After the issues were joined, the trial judge began considering the merits of the case.
Denial of Motion to Dismiss
On February 21, 1964, after the petitioners completed their presentation of evidence, the respondents filed a motion to dismiss based on jurisdictional grounds and laches. The trial judge denied this motion in an order dated March 16, 1964. Following this denial, hearings were scheduled for March 23 and April 1, 1964, to continue the case.
Respondents' Non-Appearance
The respondents failed to appear for both hearing dates, prompting the petitioners to request case submission based on the evidence presented so far. When the case was called again on April 1, 1964, the respondents were again absent. They subsequently filed a motion for reconsideration regarding the trial judge's denial of their motion to dismiss, citing excusable neglect for their absence due to notification issues with their counsel.
Opposition and Rejoinder
Petitioners filed an opposition to this motion, asserting it lacked proper verification and was intended to delay proceedings. They contended that the motion for reconsideration should not suspend the hearing of the case. On April 23, 1964, the respondents provided additional arguments and evidence to support their motion.
Ruling of the Trial Court
On May 20, 1964, the trial court found the respondents guilty of unfair labor practices, ordering the reinstatement of the petitioners with back wages. The court's findings emphasized a pattern of discrimination against union members that arose after the petitioners joined a labor union, ultimately leading to their non-reinstatement following a branch reconstruction.
Motion for Reconsideration and CIR En Banc Resolution
Respondents filed a motion for reconsideration of the trial court's order, which was accompanied by arguments reiterating their prior claims. The CIR en banc later issued a resolution on October 14, 1964, which set aside the trial judge’s order and returned the case for further proceedings, primarily for the reception of evidence from the respondents, but also acknowledged the motion for reconsideration filed earlier.
Supreme Court's Review and Key Legal Issues
The Supreme Court determined whether a trial judge's proceedings are suspended upon filing a motion for reconsideration of an interlocutory order. It established that interlocutory orders, like the one denying a motion to dismiss, should not suspend hearings and should remain unappealable.
Rationale on Interlocutory Orders
The Court underscored the importance of not allowing interlocutory orders to disrupt ongoing proceedings, as allowing such delays leads to the poten
...continue readingCase Syllabus (G.R. No. 148560)
Case Background
- On December 10, 1962, a complaint was filed in the Court of Industrial Relations (CIR) by the acting prosecutor on behalf of forty-three employees of La Perla Cigar and Cigarette Factory, Inc., against the company and its manager, Lorenzo Lim, alleging unfair labor practices.
- The case was assigned the docket number 3377-ULP.
- Respondents filed an answer on January 7, 1963, admitting and denying various allegations and requesting the case's dismissal.
Procedural History
- The trial judge, Jose Bautista, commenced hearings on the merits after issues were joined.
- On February 21, 1964, after the complainants closed their evidence, respondents moved to dismiss the case, claiming the CIR lacked jurisdiction and that the complaint was barred by laches.
- The motion to dismiss was denied on March 16, 1964, prompting the judge to schedule further hearings for March 23 and April 1, 1964.
- Respondents failed to appear at both scheduled hearings, leading complainants to request submission of the case based on the evidence already presented.
Respondents’ Motions and Hearings
- Respondents filed a motion for reconsideration on March 24, 1964, regarding the denial of their motion to dismiss.
- On April 2, 1964, respondents submitted an unverified motion claiming their absence was due to excusable neglect, as they had n