G.R. No. 148470. April 29, 2005
LOPEZ DELA ROSA DEVELOPMENT CORPORATION and GLORIA DELA ROSA LOPEZ, Petitioners, vs. HON. COURT OF APPEALS, NATIONAL LABOR RELATIONS COMMISSION, LABOR ARBITER VICENTE LAYAWEN and ARIEL CHAVEZ, Respondents.

FACTS

Respondent Ariel Chavez filed a complaint for illegal dismissal and various monetary claims against petitioners Lopez Dela Rosa Development Corporation and its president, Gloria Dela Rosa Lopez. Chavez alleged he was employed as a building maintenance worker starting June 1, 1993, with a daily wage of PHP 120.00. He claimed he worked long hours without overtime pay, was denied statutory benefits, and was illegally dismissed on December 8, 1994, after requesting a salary adjustment to the minimum wage. Petitioners countered that Chavez was hired under a fixed-term employment contract from January 2 to December 31, 1994, on a “no work, no pay” basis, with free housing and rice rations as part of his compensation. They asserted he was legally terminated for abandonment, having failed to report for work from December 8 to 14, 1994.
The Labor Arbiter ruled in favor of Chavez, declaring his dismissal illegal and awarding monetary benefits. The NLRC affirmed this decision. Petitioners elevated the case to the Court of Appeals via a petition for certiorari. The CA dismissed the petition, finding that the petitioners failed to file a motion for reconsideration of the NLRC decision before resorting to certiorari, thereby failing to exhaust administrative remedies. The CA also found no grave abuse of discretion in the NLRC’s findings.

ISSUE

Whether the Court of Appeals erred in dismissing the petition for certiorari due to the petitioners’ failure to file a motion for reconsideration before the NLRC.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The Court held that the filing of a motion for reconsideration is a mandatory precondition for the filing of a petition for certiorari under Rule 65, as it affords the tribunal an opportunity to correct its own errors. The NLRC Rules of Procedure explicitly require such a motion. Petitioners’ failure to comply with this procedural requirement was fatal to their case. The Court rejected the petitioners’ argument that their petition fell under recognized exceptions to the rule, such as where a motion for reconsideration would be useless. The petitioners merely alleged that the NLRC decision was void for lack of jurisdiction, but the Court found this claim unsubstantiated. The NLRC clearly had jurisdiction over the appeal from the Labor Arbiter’s decision. Since the petitioners did not avail of the plain, speedy, and adequate remedy of a motion for reconsideration, the CA correctly dismissed their petition for certiorari. The Court emphasized that rules of procedure must be faithfully followed to ensure orderly administration of justice.