G.R. No. L-73140 May 29, 1987
RIZAL EMPIRE INSURANCE GROUP AND/OR SERGIO CORPUS, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, TEODORICO L. RUIZ, as Labor Arbiter and ROGELIO R. CORIA, respondents.

FACTS

Private respondent Rogelio R. Coria was hired by petitioner Rizal Empire Insurance Group in August 1977 as a casual employee. He was regularized on January 1, 1978, appointed as a clerk-typist. Over his tenure, he received consistent promotions and salary increases, being transferred to the Claims Department, Underwriting Department, and finally to the Fire Division where he was made an inspector by July 1983. On October 15, 1983, he was dismissed from service on the grounds of alleged tardiness and unexcused absences. Coria filed a complaint for illegal dismissal. Labor Arbiter Teodorico L. Ruiz ruled in his favor, ordering reinstatement with back wages in a decision dated March 14, 1985.
Petitioners received the Labor Arbiter’s decision on April 1, 1985. They filed a Motion for Extension of Time to File Memorandum of Appeal on April 11, 1985, and subsequently filed the actual Memorandum of Appeal on April 22, 1985. The National Labor Relations Commission (NLRC), in a Resolution dated November 15, 1985, dismissed the appeal for having been filed out of time. The NLRC strictly applied its Revised Rules, which mandate that an appeal from a Labor Arbiter’s decision must be perfected within ten calendar days and explicitly state that no motion for extension of time shall be entertained. Petitioners then elevated the matter to the Supreme Court via certiorari.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in dismissing the petitioners’ appeal for being filed out of time based on a strict application of its procedural rules.

RULING

The Supreme Court dismissed the petition, upholding the NLRC’s dismissal of the appeal. The Court emphasized that the Revised Rules of the NLRC are clear, explicit, and leave no room for interpretation. Rule VIII, Section 1 requires an appeal to be filed within ten calendar days from receipt of the Labor Arbiter’s decision, and Section 6 expressly states that no motion for extension of that period shall be entertained. Petitioners’ invocation of the Rules of Court provision on liberal construction to attain substantial justice was unavailing. The Court ruled that the NLRC’s procedural rules have the force of law and are entitled to great respect, as they are enacted by the administrative body entrusted to enforce labor laws. Since the petitioners filed their appeal beyond the non-extendible ten-day period, the Labor Arbiter’s decision had become final and executory, beyond the Court’s power to review. The Court further noted that, even assuming it could review the merits, the Labor Arbiter’s finding of illegal dismissal was correct, as the employee’s consistent promotions indicated satisfactory performance, making dismissal for occasional lapses too severe a penalty.