GR 78576; (July, 1991) (Digest)
G.R. No. 78576 ; July 31, 1991
FILCON MANUFACTURING CORPORATION and EDWARDSON MANUFACTURING CORPORATION, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION and CONFEDERATION OF FREE LABORERS (CFL), respondents.
FACTS
Petitioner Edwardson Manufacturing Corporation, facing foreclosure, sold its assets in April 1983 and subsequently closed its business operations in October 1983, terminating all employees, including the twelve private respondents. The employees received separation pay and executed releases and quitclaims. However, the private respondents, through their union (CFL), filed a complaint for illegal dismissal and non-payment of vacation and sick leave pay against Edwardson and Filcon Manufacturing Corporation. They alleged the sale was a scheme to evade liability and that they were coerced into accepting reduced benefits.
Labor Arbiter Cornelio Linsangan initially ruled in favor of the employees, ordering reinstatement with backwages and payment of leave benefits. Upon remand for reconsideration, the Labor Arbiter reaffirmed his decision, crediting the employees’ joint affidavit over the corporations’ documentary evidence. The Arbiter found the employees’ testimonies sincere and persistent, concluding their dismissals were illegal.
ISSUE
Whether the National Labor Relations Commission committed grave abuse of discretion in dismissing the petitioners’ appeal for being filed two days late.
RULING
No, the NLRC did not commit grave abuse of discretion. The Supreme Court emphasized that the perfection of an appeal within the reglementary period is both mandatory and jurisdictional. Failure to comply renders the judgment final and executory. The petitioners filed their appeal two days beyond the prescribed period. Consequently, the Labor Arbiter’s decision had attained finality and could no longer be altered.
The Court held that the doctrine of finality of judgment is a fundamental policy grounded on public interest and sound practice. Once a judgment becomes final, the winning party acquires a right to its execution, and the court loses jurisdiction to amend it substantively. The NLRC’s dismissal of the belated appeal was a correct application of this principle and did not constitute a capricious, arbitrary, or despotic exercise of judgment amounting to grave abuse of discretion. The petition for certiorari was therefore dismissed for lack of merit.