Case Summary (G.R. No. 143557)
Factual Background
On September 21, 1995, Engineer Yolibelle S. Avinante, a Labor and Employment Officer at DOLE, requested various documents from the University of Immaculate Conception, including employee lists, payrolls, and evidence of compliance with 13th month pay regulations. Following a second request for further documents on September 26, 1995, Sister Maria Jacinta De Belen sought an injunction against the inspection. Despite this, Avinante conducted the inspection on October 17, 1995, but was denied access by the petitioners. Consequently, a Notice of Inspection Results was issued, revealing violations of labor laws.
Administrative Proceedings
On July 22, 1996, after an investigation, the Regional Director of DOLE found the petitioners liable for labor law violations and ordered them to pay ₱2,339,752.74 to 193 affected employees. The petitioners' motion for reconsideration was denied on November 11, 1996. A subsequent appeal resulted in an order dated May 2, 1997, which modified the original labor law violation penalty, reducing the payment to ₱38,967.50 for 15 employees due to underpayment of cost of living allowances.
Court of Appeals Proceedings
Petitioners filed a petition for certiorari with the Court of Appeals on May 13, 1999, after their reconsideration motions were denied. The Court of Appeals dismissed this petition due to lateness, noting that the timeframe allowed for filing a petition had expired. The appeals process indicated that only one motion for reconsideration is permitted to interrupt the 60-day period for filing a subsequent certiorari petition.
Legal Principles Involved
The dismissal of the petition was grounded in specific procedural rules—particularly, the Rules on the Disposition of Labor Standards Cases, which articulate that a second motion for reconsideration cannot toll the period for filing a certiorari petition. The high court referenced previous rulings that affirmed these limits and reiterated that extraordinary remedies like certiorari require strict adherence to procedural rules.
Supreme Court's Ruling
The Supreme Court upheld the resolutions of the Court of Appeals, concluding that the petitioners had indeed failed to comply with the timeframes
...continue readingCase Syllabus (G.R. No. 143557)
Overview of the Case
- The case involves a petition for review on certiorari under Rule 45 of the 1997 Rules of Civil Procedure.
- Petitioners include the University of Immaculate Concepcion and Sister Maria Jacinta de Belen, RVM.
- Respondents are the Secretary of Labor and Employment, Engineer Yolibelle S. Avinante, and Estelita B. Pulido.
- The primary legal question pertains to the timeliness of the petition and the validity of motions for reconsideration filed by the petitioners.
Factual Background
- On September 21, 1995, Engineer Yolibelle S. Avinante, a Labor and Employment Officer from DOLE, sent a notice to the University requesting the inspection of essential documents, including business permits and payrolls.
- A follow-up notice was sent on September 26, 1995, seeking additional documentation covering a more extended period.
- Upon receiving this second notice, Sister Maria Jacinta de Belen filed a motion to enjoin the inspection.
- The inspection occurred on October 17, 1995, but access to records was denied, prompting Avinante to issue a "Notice of Inspection Results" citing labor law violations.
Proceedings and Findings
- On July 22, 1996, the Regional Director of DOLE found the Univ