Case Summary (G.R. No. 110226)
Background Facts
In 1985, the petitioners, who were rank-and-file employees and members of the Philtread Workers Union, availed themselves of a voluntary retrenchment program with the assurance of priority re-employment should Philtread recover from financial difficulties. In late 1986, when the company resumed operations and began hiring new staff without considering the petitioners, they sought re-employment, which was ignored. This led to a formal complaint for unfair labor practices against Philtread on December 5, 1988.
Procedural Developments
In the ensuing proceedings, Philtread moved to dismiss the complaint, arguing a lack of jurisdiction as the conflict should be interpreted through the lens of the Collective Bargaining Agreement (CBA) and was thus the realm of regular courts, while petitioners contended that the matter fell within the NLRC’s jurisdiction due to the nature of unfair labor practices. The Labor Arbiter initially dismissed the complaint but ordered Philtread to prioritize the petitioners in hiring.
NLRC's Initial Ruling
After petitioners appealed, the NLRC, on April 15, 1992, reversed the Labor Arbiter's decision and mandated Philtread to re-employ the petitioners. Philtread contested the NLRC's ruling, claiming procedural issues regarding the service of the resolution. The NLRC later acknowledged a motion for reconsideration filed by Philtread, leading to a resolution on November 18, 1992, that dismissed the complaint on grounds that petitioners should have raised their issues in voluntary arbitration.
Claim of Finality
Petitioners asserted that the April 15, 1992, resolution had become final and executory since Philtread failed to file a timely motion for reconsideration. They argued that the delay in sending the resolution caused by the law firm's administrative issues should not retroactively impede the resolution's finality. The NLRC's subsequent April 7, 1993 ruling reaffirmed the November 18 resolution, asserting jurisdiction issues related to the CBA.
Court's Analysis on Finality and Jurisdiction
The Supreme Court emphasized that the NLRC's adherence to its own procedural rules regarding the timely filing of motions for reconsideration is mandatory, citing Article 223 of the Labor Code. It confirmed that Philtread's motion was filed late, rendering it ineffective. Additionally, the higher court clarified the jurisdictional divide between the Labor Arbiter and the voluntary arbitrator, noting that the NLRC had valid jurisdiction over the in
...continue readingCase Syllabus (G.R. No. 110226)
Case Overview
- Petitioners: Alberto S. Silva, Edilberto Viray, Angeles Baron, and others, former employees of Philtread (Firestone) Tire and Rubber Corporation.
- Respondents: National Labor Relations Commission (NLRC) and Philtread (Firestone) Tire and Rubber Corporation.
- Date of Decision: June 19, 1997.
- Case Reference: G.R. No. 110226.
Background Facts
- In 1985, petitioners, then employees of Philtread, participated in a retrenchment program with an understanding of priority for re-employment if the company recovered.
- By November 1986, Philtread had expanded operations and hired new personnel, prompting petitioners to apply for re-employment, which was ignored.
- On December 5, 1988, petitioners filed a complaint with the NLRC for unfair labor practice (ULP), damages, and attorney's fees against Philtread.
Legal Proceedings
- Philtread moved to dismiss the complaint, arguing that:
- The NLRC lacked jurisdiction over the case.
- Petitioners had no standing to sue as they were not privy to the Collective Bargaining Agreement (CBA).
- The Labor Arbiter dismissed the complaint but directed Philtread to give petitioners priority in hiring.
- Petitioners appealed to the NLRC, which issued a resolution on April 15, 1992, reversing the Arbiter's decision and ordering Philtread to re-employ the petitioners.
NLRC Resolutions
- On May 20, 1992, Philtread&#