Title
Tres Reyes vs. Maxim's Tea House
Case
G.R. No. 140853
Decision Date
Feb 27, 2003
Driver Ariel Tres Reyes, employed by Maximas Tea House, was dismissed after a collision caused by a speeding truck. The Supreme Court ruled his dismissal illegal, finding no gross negligence, and ordered reinstatement with backwages.
collision
wrongful termination
appeal
A

Case Summary (G.R. No. 140853)

Factual Background

Petitioner was employed since October 1995 and assigned to its Manila branch. In the early morning of September 27, 1997, he was driving the van along Julia Vargas Street in Pasig City toward Meralco Avenue at an estimated speed of 50 to 60 kilometers per hour. He had been instructed to fetch employees of Savannah Moon located in Libis, Quezon City. As petitioner approached the relevant intersection, he noticed an oncoming ten-wheeler truck traveling at full speed despite the truck being in the lane with a red signal light. Petitioner attempted to avoid the collision. Despite the maneuver, the van struck the truck, causing injuries to petitioner and seven passengers and damaging both vehicles.

On October 15, 1997, Maxims required petitioner to submit a written explanation within forty-eight hours concerning the incident. Petitioner complied, but Maxims found his explanation unsatisfactory and issued a preventive suspension for thirty (30) days, effective October 20, 1997. On November 19, 1997, Maxims terminated petitioner for cause. Petitioner believed the vehicular accident did not justify his dismissal and filed a complaint for illegal dismissal, docketed as NLRC NCR Case No. 00-12-08773-97.

Proceedings Before the Labor Arbiter

The Labor Arbiter rendered a decision on July 20, 1998 sustaining the validity of petitioner’s dismissal. The Labor Arbiter ordered, however, the payment of monetary benefits, totaling P 11,788.00, including financial assistance, thirteenth month pay for 1997, and service incentive leave pay. In its findings, the Labor Arbiter held that petitioner was grossly negligent for failing to avoid the collision.

Instead of filing the required pleading for appeal, petitioner filed a Motion for Partial Reconsideration with the NLRC on October 8, 1998. The NLRC treated the motion as an appeal and docketed it as NLRC CA No. 017339-98.

NLRC Ruling on Appeal

On March 11, 1999, the NLRC reversed the Labor Arbiter. It vacated the Labor Arbiter’s decision and ordered Maxims Tea House to reinstate petitioner to his former position without loss of seniority rights and to award full backwages. If reinstatement was no longer feasible, the NLRC ordered payment of separation pay of one month for every year of service, computed from October 7, 1995 to the date of the NLRC decision, plus backwages computed from November 19, 1997 up to the date of decision. Other reliefs were denied for lack of merit.

Maxims moved for reconsideration, but the NLRC denied the motion on May 12, 1999. Maxims thereafter instituted a special civil action for certiorari before the Court of Appeals, docketed as CA-G.R. SP No. 54110.

Court of Appeals Proceedings

In CA-G.R. SP No. 54110, Maxims alleged that the NLRC committed grave abuse of discretion amounting to want or excess of jurisdiction. The allegations centered on two matters: first, that the NLRC gave due course to petitioner’s Motion for Partial Reconsideration despite its being a prohibited pleading under Sec. 19, Rule V of the NLRC Rules of Procedure, and despite supposed noncompliance with timeliness; and second, that the NLRC substituted its own factual findings for those of the Labor Arbiter.

On November 22, 1999, the Court of Appeals granted the petition of the employer. It set aside the NLRC decision and dismissed the complaint for “utter lack of merit.”

Issues Raised in the Supreme Court

Petitioner sought review on two principal assignments of error. First, he argued that the Court of Appeals erred in holding that the NLRC committed grave abuse of discretion in treating the Motion for Partial Reconsideration as an appeal. Second, he asserted that the Court of Appeals erred in concluding that the accident was due to petitioner’s negligence as found by the Labor Arbiter, especially because the Labor Arbiter had decided the case without trial-type hearing, and because the NLRC and supporting evidence negated a finding of gross negligence.

The Supreme Court reduced the controversy into two issues: whether the Motion for Partial Reconsideration could be treated as an appeal, and whether petitioner’s dismissal was legally justified.

The Parties’ Contentions on the First Issue: Treatment of the Motion as an Appeal

Petitioner argued that, although a motion for reconsideration of a Labor Arbiter’s decision is generally prohibited, the NLRC may treat it as an appeal if it complies with all requisites for perfecting an appeal. He invoked labor law policy that procedural rules should be liberally construed to achieve just, expeditious, and inexpensive resolution. He contended that technicalities should not defeat substantial rights. The Office of the Solicitor General filed a manifestation and motion in lieu of comment agreeing with petitioner and maintaining that the NLRC properly treated the pleading as an appeal.

Maxims countered that even if the NLRC correctly treated the motion as an appeal, petitioner still failed to comply with other requirements for perfecting an appeal. In particular, Maxims argued that the motion did not include the statement required under Sec. 3, Rule VI—specifically, the date when petitioner received the appealed decision—to determine timeliness. Maxims also pointed to alleged failure to pay the required filing fees and claimed the pleading was fatally defective for lack of verification and lack of proof it was filed within the period.

Legal Basis and Reasoning on the First Issue

The Court acknowledged that, strictly speaking, a motion for reconsideration of a Labor Arbiter’s decision is prohibited under Sec. 19, Rule V of the NLRC Rules of Procedure. The same rule, however, allows that such motion “shall be treated as an appeal” if it meets all the requisites for perfecting an appeal.

The Court scrutinized the records, particularly the questioned pleading, and rejected the Court of Appeals’ finding that the Motion for Partial Reconsideration failed to contain a statement of when petitioner received the Labor Arbiter’s decision. The lead paragraph of petitioner’s motion stated that the copy of the Labor Arbiter’s decision was received on September 28, 1998. The Court held that this satisfied Sec. 3, Rule VI, which requires the statement of the date when the appellant received the appealed decision.

The Court further held that petitioner filed the pleading on October 8, 1998, which was within the ten-day period prescribed by Sec. 1, Rule VI of the NLRC Rules of Procedure. It emphasized that, for purposes of timeliness, an appeal filed on the last day of the prescribed period is still seasonably filed. It also ruled against the claim that petitioner’s motion was not verified. The records showed petitioner verified the motion to reconsider on October 8, 1998, the same day it was filed. The Court therefore concluded that petitioner substantially complied with the verification requirement under Sec. 3, Rule VI.

On the alleged failure to pay the appeal fee, the Court noted that the NLRC’s decision found that petitioner had paid P 110.00 in cash as appeal fee on October 8, 1998 and that he was issued an official receipt. The Court held that this finding refuted Maxims’ assertion, and it observed that Maxims’ contrary averments were unsupported and contradicted by the records.

Having found no basis in the record for the Court of Appeals’ conclusions on these technical issues, the Supreme Court held that the Court of Appeals erred in finding grave abuse of discretion. It reiterated that in labor cases, procedural rules should not be applied in a rigid and technical manner. They are tools intended to facilitate justice, and when strict adherence would frustrate rather than promote substantial justice, technicalities should be avoided. The Supreme Court thus determined that the NLRC did not commit grave abuse of discretion in giving due course to the pleading and treating it as an appeal.

The Parties’ Contentions on the Second Issue: Legality of Dismissal and Negligence

On the second issue, petitioner argued that the Court of Appeals erred in sustaining the Labor Arbiter’s finding of gross negligence by relying on a supposed advantage of observing demeanor of the litigants. Petitioner emphasized that no trial-type hearing was conducted. The Labor Arbiter decided based on position papers. Petitioner also argued that substantial evidence showed no gross negligence on his part, because the accident resulted from the truck driver’s fault. The OSG supported this view, pointing out that the police report indicated that the ten-wheeler lost its brakes, intruded into petitioner’s lane, and collided with petitioner’s van.

Maxims countered that the factual findings of the Labor Arbiter were correctly upheld by the Court of Appeals, and that the Labor Arbiter’s evaluation of the evidence made its findings final and conclusive.

Legal Basis and Reasoning on the Second Issue

The Court recognized that negligence is ordinarily a question of fact and that it typically does not reweigh facts. It also acknowledged that factual findings of quasi-judicial bodies like the NLRC are accorded respect and even finality when they coincide with those of the Labor Arbiter and are supported by substantial evidence. It nonetheless held that when NLRC and Labor Arbiter findings contradict each other, the reviewing court may examine the records to resolve the issue.

The Court found that proceedings before the Labor Arbiter involved primarily the submission of position papers. No trial-type hearing occurred. It therefore ruled that the Court of Appeals’ reliance on the Labor Arbiter’s presumed advantage in observing demeanor had no foundation. Based on the police traffic accident investigation report, the Court concluded that the accident was due to the ten-wheeler truck driver’s fault. It found that the truck driver saw the signal light change to red and applied the brake three times, but the truck could not stop. Because the truck was on the wrong lane, petitioner’s van,

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