G.R. No. 178477; July 16, 2012
HEIRS OF RAMON B. GAYARES, represented by Emelinda Gayares and Rhayan Gayares, Petitioners, vs. PACIFIC ASIA OVERSEAS SHIPPING CORPORATION and KUWAIT OIL TANKER, CO., S.A.K., Respondents.

FACTS

Ramon B. Gayares was hired as an Able Seaman in 1998 but was medically repatriated shortly after. He filed a complaint for disability benefits, alleging his illness was work-connected. The Labor Arbiter ruled in his favor, awarding disability benefits and sickness allowance. Upon appeal, the National Labor Relations Commission (NLRC) modified the decision, deleting the disability benefits but affirming the sickness allowance. The NLRC found Gayares failed to prove his illness was work-related, noting it manifested shortly after embarkation and was considered hereditary. Petitioners, Gayares’ heirs, received the NLRC Resolution denying their motion for reconsideration on January 3, 2007.
The 60-day period to file a Petition for Certiorari under Rule 65 with the Court of Appeals expired on March 4, 2007. Instead of filing the petition, petitioners filed a Motion for Extension of Time on March 5, 2007, citing their counsel’s heavy workload as the reason for needing an extension.

ISSUE

Whether the Court of Appeals gravely erred in denying the Motion for Extension of Time to file the Petition for Certiorari.

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the CA’s denial. Under Section 4, Rule 65 of the Rules of Court, an extension of the 60-day period to file a certiorari petition may be granted only for “compelling reasons.” The Court has consistently ruled that a lawyer’s heavy workload, standing alone, does not constitute a compelling reason. It is a routine occurrence in legal practice and does not justify a failure to comply with a procedural deadline set by law. The period for filing a special civil action for certiorari is non-extendible, and exceptions are strictly construed.
The Court emphasized that procedural rules are not to be disregarded simply because a case involves a labor dispute. While the policy is to afford protection to labor, this does not justify a blatant disregard of the rules of procedure. Adherence to procedural timelines is essential to the orderly administration of justice. The petitioners’ failure to file the petition on time rendered the NLRC decision final and executory. The Court also declined to rule on the substantive merits of the labor case, as the petition was dismissed on the procedural ground of being filed out of time. The denial of the motion for extension was therefore proper.