Case Summary (G.R. No. 143789)
Factual Background
The petitioner corporation was engaged in electrical installation and employed electricians. The private respondents were employed as electricians on one of the corporation’s projects. The private respondents filed a complaint for illegal dismissal and for nonpayment of backwages, service incentive pay, premium pay, separation pay and other allowances.
Trial Court and NLRC Proceedings
The Labor Arbiter ruled in favor of the private respondents, ordering reinstatement and backwages. The National Labor Relations Commission affirmed the Labor Arbiter’s decision. Petitioners received the NLRC decision on August 10, 1999 and filed a motion for reconsideration on August 20, 1999. The NLRC denied the motion for reconsideration by resolution received by petitioners on November 25, 1999.
Court of Appeals Proceedings
Petitioners filed a petition for certiorari under Rule 65 with the Court of Appeals on January 24, 2000. The Court of Appeals issued a Resolution dated February 15, 2000 dismissing the petition for failure to comply with procedural requirements, specifically that the petition was filed out of time and that the petition did not include certification of the documents and material portions referred to in the petition. On motion for reconsideration, the Court of Appeals, in its June 22, 2000 Resolution, relied on Cadayona vs. Court of Appeals, G.R. No. 128772, February 3, 2000, to accept petitioners’ contention that only the assailed NLRC resolution needed certification, but nonetheless denied reconsideration on the ground that the petition for certiorari was filed beyond the sixty-day period prescribed by Section 4, Rule 65.
Court of Appeals’ Computation of the Filing Period
The Court of Appeals computed the sixty-day reglementary period under Section 4, Rule 65 by counting from petitioners’ receipt on August 10, 1999 of the NLRC resolution that dismissed the appeal, allowing interruption by the motion for reconsideration filed on August 20, 1999, and resuming computation from petitioners’ receipt on November 25, 1999 of the resolution denying the motion for reconsideration. The court concluded that petitioners had fifty remaining days or until January 14, 2000 to file the petition for certiorari, and that the January 24, 2000 filing was therefore late.
Issue Presented
Whether the amendment under A.M. No. 00-2-03-SC, which provides that the sixty-day period to file a petition for certiorari shall be counted from notice of the denial of a motion for reconsideration, applied to the present petition so as to render the January 24, 2000 filing timely.
Petitioners’ Contentions
Petitioners argued that A.M. No. 00-2-03-SC, which took effect on September 1, 2000, amended Section 4, Rule 65 so as to reckon the sixty-day period from notice of the denial of a motion for reconsideration and that the amendment should be applied to their case. Petitioners asserted that a motion for reconsideration is a mandatory pleading before filing a petition for certiorari and that remedial rules should be liberally construed to afford litigants ample opportunity and to avoid denial of substantial justice by legal technicalities.
Respondents’ Contentions
Respondents opposed the petition on the ground that the question was not one of liberality and that allowing petitioners’ plea would invite similar requests and multiplicity of exceptions. Respondents emphasized the policy favoring workers in labor disputes and contended that neglect of counsel did not warrant treating the case as an exception to the rule.
Supreme Court’s Legal Analysis
The Court held that the amendment under A.M. No. 00-2-03-SC should be deemed applicable. The Court explained that remedial statutes and procedural rules that do not create new substantive rights but merely regulate remedy or procedure do not fall within the prohibition against retroactive laws and are properly construed to apply to actions pending and undetermined at the time of their enactment. The Court cited authority for the proposition that procedural laws operate retroactively to pending cases and that no vested right ordinarily attaches to procedural rules, citing Castro vs. Sagales, 94 Phil. 208, Gregorio vs. Court of Appeals, 26 SCRA 229, Tinio vs. Mina, 26 SCRA 512, and Billones vs. CIR
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Case Syllabus (G.R. No. 143789)
Parties
- Systems Factors Corporation and Modesto Dean were the petitioners in the petition for certiorari filed in the Court of Appeals.
- National Labor Relations Commission, Ronaldo Lazaga, and Luis C. Singson were the respondents in the petition before the Court of Appeals and in this Supreme Court matter.
- The Labor Arbiter and the NLRC acted as adjudicative bodies whose resolutions were assailed in the ensuing certiorari proceedings.
Key Facts
- Systems Factors Corporation employed private respondents as electricians on a project.
- Ronaldo Lazaga and Luis C. Singson filed a complaint for illegal dismissal and nonpayment of various monetary claims.
- The Labor Arbiter ordered petitioners to reinstate private respondents and to pay backwages.
- The NLRC affirmed the Labor Arbiter's decision and its judgment was allegedly received by petitioners on August 10, 1999.
- Petitioners filed a motion for reconsideration on August 20, 1999, which the NLRC denied by resolution dated November 11, 1999 and received by petitioners on November 25, 1999.
Procedural Posture
- Petitioners filed a petition for certiorari under Rule 65 with the Court of Appeals on January 24, 2000 in CA-G.R. SP No. 56849.
- The Court of Appeals issued a resolution on February 15, 2000 dismissing the petition for failure to comply with procedural requirements, specifically untimeliness and incomplete certification.
- The Court of Appeals denied the motion for reconsideration on June 22, 2000 after applying Cadayona v. Court of Appeals, G.R. No. 128772, February 3, 2000, but reaffirmed that the petition was filed out of time.
- Petitioners filed the present petition with the Supreme Court challenging the Court of Appeals' resolutions.
Issue
- Whether the amendment under A.M. No. 00-2-03-SC to Section 4, Rule 65 of the 1997 Rules of Civil Procedure, which counts the sixty-day period from notice of denial of a motion for reconsideration, is applicable to petitions already filed or pending before its effective date.
Contentions
- Petitioners contended that A.M. No. 00-2-03-SC should govern their case because it took effect on September 1, 2000 and would render their January 24, 2000 filing timely when the sixty-day period is counted from receipt of the denial of the motion for reconsideration.
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