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 National Labor Relations Commission (NLRC) affirmed this decision. Petitioners filed a Petition for Certiorari with the Court of Appeals (CA), which was dismissed for being filed out of time. The CA noted that the petitioners received the NLRC Resolution on April 17, 2000, but filed their motion for reconsideration only on April 28, 2000, which was one day beyond the 10-day reglementary period. Consequently, the NLRC resolution had become final and executory.

ISSUE

Whether the Court of Appeals erred in dismissing the Petition for Certiorari on the ground of finality of the NLRC decision due to petitioners’ late filing of a motion for reconsideration.

RULING

The Supreme Court denied the petition and affirmed the CA’s decision. The Court held that the perfection of an appeal within the statutory period is mandatory and jurisdictional. The NLRC Rules explicitly provide that a motion for reconsideration must be filed within ten (10) calendar days from receipt of the decision. The petitioners admitted receiving the NLRC Resolution on April 17, 2000. Counting ten calendar days, the last day to file the motion was April 27, 2000. Their filing on April 28, 2000, was indisputably one day late. This failure to comply with the reglementary period rendered the NLRC decision final and unappealable. The Court emphasized that the doctrine of finality of judgments is grounded on public policy and the necessity for order and conclusiveness in judicial proceedings. A decision that has attained finality becomes immutable and unalterable. The CA, therefore, correctly dismissed the petition for certiorari, as the assailed NLRC resolution was no longer subject to review, having lapsed into finality. The petitioners’ attempt to raise substantive arguments on the merits of the labor case could not be entertained, as the procedural lapse foreclosed any further appellate review.