GR 166594; (July, 2006) (Digest)
G.R. No. 166594 ; July 20, 2006
CIUDAD FERNANDINA FOOD CORPORATION EMPLOYEES UNION-ASSOCIATED LABOR UNIONS, ET AL., petitioners, vs. HON. COURT OF APPEALS and CIUDAD FERNANDINA FOOD CORPORATION, ET AL., respondents.
FACTS
Petitioners, members of the Ciudad Fernandina Employees Union, filed a complaint for illegal closure, nonpayment of salaries, and other monetary claims against respondent Ciudad Fernandina Food Corporation (CFFC). The Labor Arbiter ruled in favor of the petitioners, ordering their reinstatement with full backwages and payment of service incentive leave and 13th month pay. CFFC sought to appeal this decision to the NLRC.
To perfect its appeal, CFFC filed a Motion for Reduction of Supersedeas Bond within the reglementary period but failed to actually post the required bond, whether in full or in the reduced amount it sought. The NLRC consequently dismissed the appeal for non-perfection, declaring the Labor Arbiter’s decision final and executory. The Court of Appeals reversed the NLRC, ruling that the filing of the motion for bond reduction tolled the appeal period and that the NLRC should have first resolved the motion.
ISSUE
Whether the filing of a motion for reduction of supersedeas bond, without posting a bond, tolls the reglementary period for perfecting an appeal from a Labor Arbiter’s decision.
RULING
No. The Supreme Court reinstated the NLRC’s dismissal of the appeal. The posting of a cash or surety bond is a mandatory and jurisdictional requirement for perfecting an appeal in labor cases involving monetary awards, as prescribed by the NLRC Rules of Procedure. The Court emphasized that the reglementary period to appeal is not suspended by the mere filing of a motion for bond reduction.
The legal logic is clear: the requirement to post a bond is indispensable for the NLRC to acquire jurisdiction over the appeal. CFFC’s failure to post any bond—either the full amount or a provisional bond equivalent to the monetary award due under the decision—within the 10-day appeal period rendered its appeal incomplete and ineffective. The filing of a motion for reduction is not a substitute for compliance. To hold otherwise would allow dilatory tactics and undermine the finality of labor decisions. Thus, the NLRC correctly denied the appeal for non-perfection, making the Labor Arbiter’s decision final and executory.