G.R. No. 124766. January 30, 1997.
Orient Express Placement Philippines and Dominador Batenga, Jr., petitioners, vs. National Labor Relations Commission (NLRC), Hon. Labor Arbiter Ernesto Dinopol, and Ma. Luisa P. Collins, respondents.

FACTS

Petitioner Orient Express Placement Philippines employed private respondent Ma. Luisa P. Collins as a liaison officer. On November 9, 1993, she was summoned by the company president, petitioner Dominador Batenga, Jr., confronted with an accusation of exacting excessive placement fees from job applicants, and summarily dismissed on the same day. On November 17, 1993, Collins filed a complaint for illegal dismissal with monetary claims.
The Labor Arbiter ruled in favor of Collins, finding that petitioners failed to substantiate the charge against her. The evidence indicated that another officer, Jose Batenga, had directed the exaction of fees. The Labor Arbiter also held that the dismissal violated due process, as Collins was not afforded the twin requirements of notice and hearing. Consequently, the Arbiter ordered her reinstatement with backwages and awarded moral and exemplary damages and attorney’s fees. The NLRC affirmed the findings of illegal dismissal and due process violation but deleted the awards for damages and attorney’s fees, finding no proof of fraud or bad faith.

ISSUE

Whether the Supreme Court can review the NLRC decision given the procedural lapse by the petitioners.

RULING

The Supreme Court dismissed the petition. The core legal logic rests on the doctrine of finality of judgments and the mandatory nature of procedural rules. Petitioners admitted they filed their motion for reconsideration of the NLRC decision beyond the ten-day reglementary period. Under the NLRC Rules of Procedure and established jurisprudence, the failure to file a timely motion for reconsideration renders the NLRC decision final and executory after ten calendar days from receipt. Consequently, the decision can no longer be appealed or subjected to judicial review.
The Court emphasized that this procedural rule is not a mere technicality but a fundamental principle intended to ensure the orderly administration of justice and to end litigation. Since the NLRC decision had attained finality as to the petitioners due to their own tardiness, the Supreme Court lost jurisdiction to entertain the petition for certiorari. The Court also declined to grant private respondent’s prayer to reinstate the deleted awards, as she likewise filed her own motion for reconsideration out of time, making the NLRC decision final and unalterable as to her claims as well. The dismissal was thus based on the procedural ground of prematurity, without reaching the substantive merits of the illegal dismissal case.