GR 111929; (January, 1996) (Digest)
G.R. No. 111929 ; January 24, 1996
AMERICAN HOME ASSURANCE CO., INC. and/or LESLIE J. MOUAT, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION (First Division), LABOR ARBITER MANUEL R. CADAY, VIRGILIO MALINAO, ROSEMILO GACUSAN and DOMINADOR LORIAGA, respondents.
FACTS
Private respondents Virgilio Malinao, Rosemilo Gacusan, and Dominador Loriaga filed a complaint for regularization and monetary claims against petitioners. Petitioners moved to dismiss the claims of Malinao and Gacusan, alleging a compromise agreement. The respondents opposed, claiming the agreement was procured through undue influence. Labor Arbiter Caday denied the motion to dismiss but ordered Malinao and Gacusan to return the settlement money as a condition precedent for further proceedings. They failed to comply. Consequently, the Labor Arbiter dismissed their complaints with prejudice in an Order dated April 30, 1992. Loriaga’s case was later dismissed without prejudice upon his own motion.
ISSUE
Did the National Labor Relations Commission commit grave abuse of discretion in reinstating the complaints after the Labor Arbiter’s dismissal orders had become final and executory?
RULING
Yes. The Supreme Court granted the petition and reversed the NLRC. The legal logic is anchored on the mandatory and jurisdictional nature of appeal periods under labor law. Article 223 of the Labor Code requires that appeals from a Labor Arbiter’s order must be filed within ten calendar days. The record shows that the Motion to Admit the Motion for Reconsideration for Malinao was filed only on December 14, 1992, far beyond the reglementary period from the August 10, 1992, receipt of the dismissal order. For Gacusan, there was no appeal filed at all. Consequently, the dismissal orders had attained finality, and the NLRC lost jurisdiction to entertain the belated appeal. The Court also upheld the Labor Arbiter’s authority to impose the refund condition, which respondents did not challenge and failed to satisfy, justifying the dismissal of their claims. The NLRC’s act of reinstating the case despite these jurisdictional defects constituted grave abuse of discretion.