Title
Universal Robina Corp. vs. Court of Appeals
Case
G.R. No. 144978
Decision Date
Jan 15, 2002
Employees sought enhanced retirement benefits under RA 7641; SC ruled their certiorari petition timely, remanding for further proceedings due to retroactive procedural rule application.
retirement benefits
private sector
timing
A

Case Summary (G.R. No. 144978)

Factual Background

Respondents, who were employees of CFC Corporation, retired upon reaching the age of sixty. Under the company retirement plan, each of them were granted retirement benefits equivalent to one-half (1/2) month pay for every year of service. After the enactment of Republic Act No. 7641 on January 7, 1993, which provided more liberal retirement benefits for private-sector employees, respondents filed a consolidated Complaint before the National Labor Relations Commission (NLRC). Their complaint sought retroactive entitlement to the enlarged benefits under RA 7641.

After due proceedings, Labor Arbiter Eduardo J. Carpio rendered a decision on January 15, 1999 in favor of respondents. The dispositive portion ordered Universal Robina Corporation to pay respondents the following amounts: Ygana P67,494.46; Villaflor P44,456.86; and Cardinales P85,743.55.

NLRC and Motion for Reconsideration

Petitioners appealed. On September 30, 1999, the NLRC affirmed the Labor Arbiter’s decision. A copy of that NLRC resolution was received by petitioners on November 11, 1999. Petitioners then filed a Motion for Reconsideration on November 15, 1999. The NLRC denied the motion with finality through a December 29, 1999 Resolution, which petitioners received on March 14, 2000.

Proceedings in the Court of Appeals

On May 15, 2000, petitioners filed a Petition for Certiorari with the CA seeking to annul the NLRC rulings. On May 18, 2000, the CA issued the first assailed resolution dismissing the petition as filed out of time. A copy of that resolution was received by petitioners on June 23, 2000.

The CA held that Section 4, Rule 65 of the 1997 Rules of Civil Procedure generally requires that a special civil action for certiorari be filed within sixty (60) days from notice of the judgment, order or resolution sought to be assailed, and it was not contemplated that the sixty-day period be counted from receipt of a motion for reconsideration. The CA relied on the amendatory rule in the Supreme Court En Banc Resolution dated 21 July 1998 (Bar Matter No. 803), which, in the CA’s reading, allowed interruption of the period only in a manner that still resulted in lateness for petitioners.

The CA reasoned that, because petitioners received the assailed NLRC resolution on 11 November 1999 and filed their motion for reconsideration on 15 November 1999, four days had elapsed. After the motion was denied and petitioners received the denial on 14 March 2000, the CA found that the petition filed on 15 May 2000 was six days late.

On August 21, 2000, the CA denied petitioners’ Motion for Reconsideration, prompting the present recourse to the Supreme Court.

The Parties’ Contentions

In the Supreme Court, petitioners raised a lone issue: whether the CA correctly dismissed their Petition for Certiorari in CA-GR SP No. 58695 for being filed out of time.

Petitioners urged liberality in the computation of the reglementary period under Section 4, Rule 65. Respondents, in turn, opposed, maintaining the CA’s time computation and dismissal.

Central Legal Issue

The core controversy centered on the computation of the period to file a petition for certiorari under Section 4, Rule 65, particularly whether the sixty-day period should be counted from receipt of the denial of the motion for reconsideration, in view of changes to the rule effective after the CA dismissal but applied retroactively by jurisprudence to pending and undetermined actions.

Legal Basis and Reasoning

The Supreme Court acknowledged that, strictly speaking, the CA did not err in its dismissal because, at the time relevant to the CA’s determination, the prevailing framework was the July 21, 1998 amendatory rule (Bar Matter No. 803) referenced by the CA.

However, the Supreme Court emphasized that the Rule was later amended by AM No. 00-2-03-SC, effective September 1, 2000. As amended, Section 4 provided that: the petition shall be filed not later than sixty (60) days from notice of the judgment, order or resolution, and that when a motion for reconsideration or new trial is timely filed, “the sixty (60) day period shall be counted from notice of the denial of the said motion.” The Supreme Court treated this amendment as procedural or remedial in character. It did not create new rights or remove vested ones. Because it operated to further the remedy and confirm existing rights, it was given retroactive effect.

Applying that retroactive effect, the Supreme Court held that petitioners’ Petition for Certiorari was filed on time. It noted that petitioners received the NLRC resolution denying their motion for reconsideration on March 14, 2000. They then filed their petition with the CA on May 15, 2000.

The Supreme Court then performed the day-counting. It reasoned that the sixtieth day from March 14, 2000 fell on May 13, which was a Saturday. Accordingly, petitioners were entitled to file on the next working day, which was May 15, 2000.

The Supreme Court further stated that it had already ruled in a number of cases that the sixty-day period should be reckoned from receipt of the resolution denying the motion for reconsideration, and it cited Systems Factors Corporation v. National Labor Relations Commission, Unity Fishing Development Corp. v. Court of Appeals, and Pfizer Inc. v. Galan. Finally, it cited jurisprudential support that the amendment under AM No. 00-2-03-SC was deemed applicable even if the petition had been filed before September 1, 2000, on the rationale that procedural rules should apply to pending and undetermined actions.

Ruling of the Supreme Court

The Supreme Court GRANTED the petition. It SET ASIDE the CA’s assailed resolutions and REMANDED the case to the CA for further proceedings. It imposed no costs.

Doctrinal Takeaway

The decision clarified that, after the effectivity of AM No. 00-2-03-SC, Section 4, Rule 65 is construed such that, when a motion for reconsideration is timely filed, the sixty-day period for filin

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