GR 168988; (June, 2007) (Digest)
G.R. No. 168988 ; June 19, 2007
FERNANDO G. MANAYA, petitioner, vs. ALABANG COUNTRY CLUB INCORPORATED, respondent.
FACTS
Petitioner Fernando G. Manaya filed a complaint for illegal dismissal against respondent Alabang Country Club Inc. The Labor Arbiter ruled in Manaya’s favor, declaring him a regular employee and ordering his reinstatement with backwages. Respondent, through its counsel of record, Atty. Angelina A. Mailon, received a copy of this Decision on December 11, 2000. Without a formal withdrawal of appearance by Atty. Mailon, a new counsel for respondent filed a Memorandum of Appeal on December 26, 2000.
The National Labor Relations Commission (NLRC) dismissed the appeal for having been filed beyond the ten-day reglementary period, reckoning from December 11, 2000. The NLRC emphasized that the failure to perfect an appeal within the statutory period is jurisdictional, rendering the Labor Arbiter’s decision final and executory. Respondent filed a Petition for Certiorari with the Court of Appeals.
ISSUE
Whether the Court of Appeals erred in ordering the NLRC to give due course to respondent’s appeal despite its filing beyond the reglementary period.
RULING
The Supreme Court reversed the Court of Appeals and reinstated the NLRC’s dismissal of the appeal. The Court held that procedural rules, especially those governing periods for appeal, are not mere technicalities but essential to the orderly administration of justice and the prevention of needless delays. The ten-day period for appealing a Labor Arbiter’s decision is mandatory and jurisdictional.
The negligence of counsel binds the client. Respondent’s claim that its original counsel abandoned the case was unsupported by evidence of a formal withdrawal or substitution. The act of the new counsel in filing the appeal late constituted simple negligence, not the gross negligence required to exempt a client from the consequences of counsel’s actions. The Court found no compelling reason to relax the rules, as the right to appeal is a statutory privilege that must be exercised in accordance with the law. Consequently, the Labor Arbiter’s decision had attained finality.