Case Summary (G.R. No. 187104)
Applicable Law and Collective Bargaining Agreement Provision
The case is governed by the 1987 Philippine Constitution as it was decided after 1990. Key provisions are found in Section 7.7(a) of the CBAs, specifying that college teaching employees who fail yearly evaluations for three cumulative years within five years are subject to forced leave for one regular semester, during which benefits are suspended. The dispute centers on whether this provision applies cumulatively across CBAs or only within the effectivity of a single CBA.
Facts and Procedural History
Cobarrubias was placed on forced leave in the first semester of SY 2007-2008 after failing evaluations in three distinct school years (2002-2003, 2005-2006, 2006-2007), scoring below the required threshold. She contested this forced leave as illegal, exhausted the grievance mechanisms in the CBA, and eventually brought the case before the National Conciliation and Mediation Board. When mediation failed, issues were submitted to voluntary arbitration. The VA dismissed the case, relying on the SLU’s authority under the CBA to impose forced leave regardless of consecutive or separate CBA periods.
Cobarrubias filed a petition for review with the Court of Appeals (CA), which was initially dismissed due to failure to pay docket fees promptly and to attach necessary records. Upon filing a motion for reconsideration and after paying the fees late, the CA reinstated the petition. The CA then ruled that the forced leave provision applied only within the five-year duration of the applicable CBA and ordered SLU to pay the benefits suspended during Cobarrubias’ forced leave. The CA denied SLU's motion for reconsideration, leading SLU to file a petition for review on certiorari to the Supreme Court.
Central Legal Issues
The Supreme Court identified two core issues: (1) whether the CA erred in reinstating the petition despite the late payment of appellate docket fees, which is a jurisdictional prerequisite; and (2) whether the CA erred in annulling the VA’s decision and declaring the forced leave provision to be limited within the five-year effectivity of a single CBA.
Supreme Court’s Ruling on Payment of Docket Fees
The Supreme Court emphasized that the right to appeal is not absolute, but a statutory privilege subject to strict compliance with procedural rules. Under Rule 43 of the Rules of Court, appeal from the VA must be taken within fifteen days, accompanied by full payment of docket fees. Failure to comply with these prerequisites results in dismissal of the appeal and the finality of the lower decision.
The Court reaffirmed established jurisprudence from precedent cases dating back to 1932 (Lazaro v. Endencia and Andres), which consistently held that payment of the full docket fees within the reglementary period is mandatory and jurisdictional. Partial or delayed payments invalidate the appeal despite subsequent attempts to cure the defect.
Application to the Case—Procedural Lapses Fatal
Cobarrubias filed her petition within the 15-day period but paid the docket fees only 72 days later, during her motion for reconsideration. The Court found no valid or meritorious explanation for this late payment. It rejected Cobarrubias’ plea based on "ends of justice" or "fair play," emphasizing that procedural rules exist to maintain order and efficiency in judicial proceedings and must be strictly enforced, especially regarding jurisdictional matters like docket fee payments.
Exceptions to Strict Compliance Are Not Applicable
The Court examined exceptions permitting liberal construction or excusing procedural lapses, such as weighty reasons, absence of bad faith, or compelling circumstances. It found none present in Cobarrubias' case. The absence of sufficient justification for late payment proved fatal, and the Court underscored the necessity of advancing reasoned explanations to warrant relaxation of such rules.
Supreme Court’s Holding and Final Disposition
The Supreme Court held that the CA erred in reinstating Cobarrubias’ petition because it lacked jurisdiction due to non-payment of the docket fe
Case Syllabus (G.R. No. 187104)
Facts and Background of the Case
- Evangeline C. Cobarrubias, respondent, is an associate professor at Saint Louis University, Inc.’s (SLU) College of Human Sciences and an active member of the Union of Faculty and Employees of Saint Louis University (UFESLU).
- SLU and UFESLU had two relevant Collective Bargaining Agreements (CBAs) covering the periods 2001-2006 and 2006-2011, both containing a “forced leave” provision under Section 7.7 regarding teaching employees.
- Section 7.7(a) stipulates that teaching employees retained for three (3) cumulative years within five (5) years who fail the yearly evaluation are subject to forced leave for one regular semester, suspending all benefits.
- Cobarrubias was placed on forced leave for the first semester of School Year (SY) 2007-2008 after failing the evaluations for SY 2002-2003 (85 points), SY 2005-2006 (77 points), and SY 2006-2007 (72.9 points), all below the required 87 points.
- Cobarrubias challenged the forced leave through the grievance machinery of the CBA, which failed, then filed for illegal forced leave with the National Conciliation and Mediation Board (NCMB).
- With mediation unsuccessful, the parties agreed to voluntary arbitration before VA Daniel T. FariAas.
- Cobarrubias cited a prior Court of Appeals (CA) decision (CA-G.R. SP No. 90596) interpreting the forced leave to be coterminous with the CBA in force during the same five-year period.
- SLU argued the prior CA decision was not final due to a pending appeal before the Supreme Court and maintained that the forced leave applied regardless of the specific CBA period, so long as three failures occurred within any five-year period.
Voluntary Arbitrator’s Decision and Procedural History
- On October 26, 2007, VA FariAas dismissed Cobarrubias’ case, upholding SLU’s authority under the CBA to impose forced leave for three failed evaluations in any five-year span without limitation to a single CBA period.
- Cobarrubias received the VA decision on November 20, 2007.
- Cobarrubias filed a petition for review with the CA on December 5, 2007, failing to pay docket fees and to attach required documents.
- On January 14, 2008, the CA dismissed the petition for procedural lapses.
- Cobarrubias moved for reconsideration on February 15, 2008, submitting payment for the docket fees and attaching required documents, arguing justice demanded a resolution on merits.
- On July 30, 2008, the CA reinstated the petition, finding substantial compliance with procedural rules.
- SLU opposed, asserting the VA decision had already attained finality due to non-payment of appeal fees within the prescribed period.
The Court of Appeals’ Decision on the Merits
- The CA annulled the VA decision, interpreting Section 7.7(a) of the 2006-2011 CBA to mean that the “three cumulative years in five years” must fa