G.R. No. 139526 October 25, 2005
RAMATEK PHILIPPINES, INC. and MORRIS WEINBERG, Petitioners, vs. MA. ANELIA DE LOS REYES, Respondent.

FACTS

Respondent Ma. Anelia de los Reyes was hired as comptroller by petitioner Ramatek Philippines, Inc. in August 1995. In September 1995, Ramatek subcontracted with Sicar Micro-Electronics Corporation, where respondent’s husband was a major stockholder and officer. In July 1996, Sicar and the husband filed a damages case against certain Ramatek officials. Subsequently, Morris Weinberg, Ramatek’s chairman, requested via email that respondent submit a voluntary resignation due to a perceived “major conflict of interest.” Later, Ramatek sent her a notice to explain alleged questionable transactions and, after an ex-parte investigation from which she was absent, terminated her employment for breach of trust.
Respondent filed a complaint for illegal dismissal. The Labor Arbiter ruled in her favor, finding the dismissal illegal due to lack of just cause and procedural due process. The NLRC affirmed. Petitioners filed a petition for certiorari with the Court of Appeals, which dismissed it for being filed out of time. Petitioners then elevated the matter to the Supreme Court via a petition for review.

ISSUE

Whether the Court of Appeals correctly dismissed the petition for certiorari for having been filed beyond the reglementary period.

RULING

Yes, the Court of Appeals was correct. The Supreme Court affirmed the dismissal, emphasizing the mandatory and jurisdictional nature of the 60-day period for filing a petition for certiorari under Rule 65 of the Rules of Court. The NLRC issued its Resolution denying petitioners’ motion for reconsideration on December 29, 1998. Petitioners received a copy on January 8, 1999. The 60-day period to file the petition thus expired on March 9, 1999. However, petitioners filed their petition with the Court of Appeals only on March 15, 1999, which was six days late. The Court strictly applied the reglementary period, noting that procedural rules are designed to ensure the orderly administration of justice. The failure to comply renders the petition dismissible, as the right to appeal is a statutory privilege that must be exercised in accordance with the law. The Court found no compelling reason to relax the rules in this case, as the negligence of petitioners’ counsel in missing the deadline was not excusable. Consequently, the CA’s dismissal for tardiness was proper, making a review of the substantive merits of the labor case unnecessary.