GR 128389; (November, 1999) (Digest)
G.R. No. 128389 November 25, 1999
DON ORESTES ROMUALDEZ ELECTRIC COOPERATIVE, INC. (DORELCO), petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, and LINO L. PARONE, respondents.
FACTS
Lino L. Parone filed a complaint for illegal dismissal and non-payment of monetary benefits against Don Orestes Romualdez Electric Cooperative, Inc. (DORELCO). The Labor Arbiter ruled in favor of Parone, declaring him a regular employee and ordering DORELCO to pay him backwages and other benefits totaling P239,667.72. DORELCO filed a notice of appeal with the National Labor Relations Commission (NLRC) but, instead of posting the mandatory appeal bond equivalent to the monetary award, it filed a motion for reduction of the bond, citing financial difficulties due to various debts.
The NLRC issued a resolution denying DORELCO’s motion for bond reduction and directed it to post the full bond amount within a non-extendible ten-day period. DORELCO failed to comply and instead filed a motion for reconsideration. The NLRC subsequently denied this motion and dismissed the appeal for failure to perfect the appeal by posting the required bond. It later issued a resolution directing the issuance of an entry of judgment and execution of the Labor Arbiter’s decision.
ISSUE
Whether the National Labor Relations Commission acted with grave abuse of discretion in denying the motion for reduction of appeal bond, dismissing the appeal, and ordering the issuance of an entry of judgment.
RULING
The Supreme Court dismissed the petition, finding no grave abuse of discretion on the part of the NLRC. The Court emphasized that a petition for certiorari under Rule 65 requires proof of a capricious, whimsical, or arbitrary exercise of judgment equivalent to lack of jurisdiction, not merely reversible error. The posting of an appeal bond is a mandatory and jurisdictional requirement for perfecting an appeal in labor cases to ensure the awarded claims can be satisfied should the appeal fail.
The NLRC’s denial of the motion for bond reduction and its subsequent dismissal of the appeal for non-compliance were based on factual and legal justifications. DORELCO’s alleged financial hardship, due to prioritizing other debts, was not a valid excuse to circumvent the mandatory bonding requirement. The Court reiterated that it is not a trier of facts and its review power in certiorari proceedings is confined to issues of jurisdiction or grave abuse of discretion. The NLRC acted within its legal authority in insisting on compliance with procedural rules to ensure the efficacy of labor standards. Consequently, the resolutions were affirmed.