GR 150286; (October, 2003) (Digest)
G.R. No. 150286 ; October 17, 2003
ELCEE FARMS, INC., and CORAZON SAGUEMULLER, petitioners, vs. PAMPILO SEMILLANO and ONE HUNDRED THIRTY OTHERS and THE NLRC, respondents.
FACTS
Private respondents filed a complaint for illegal dismissal. The Labor Arbiter initially dismissed the claims against petitioners Elcee Farms and Saguemuller. On appeal, the NLRC modified the decision, ultimately holding petitioners solely liable for separation pay and damages to 131 claimants. Petitioners filed two separate petitions for certiorari (Rule 65) with the Supreme Court to challenge this NLRC Resolution. The first petition (G.R. No. 125714) was not filed within the granted extension period and was deemed final. The second petition ( G.R. No. 126428 ) was dismissed for petitioners’ non-compliance with a Supreme Court Resolution requiring payment of costs and submission of a memorandum, which they failed to receive as it was sent to a wrong address. With both petitions dismissed, the NLRC Resolution became final. Petitioners subsequently filed a petition for annulment of judgment with the Court of Appeals.
ISSUE
Whether the Court of Appeals correctly dismissed the petition for annulment of the NLRC decision for lack of jurisdiction.
RULING
Yes, the Court of Appeals was correct. The Supreme Court affirmed the dismissal. The legal logic is anchored on the limited scope of a petition for annulment of judgment under Rule 47 of the Rules of Court. This remedy is available only against final and executory judgments of regional trial courts. It is a remedy of last resort, confined to the civil law sphere of ordinary courts, and does not extend to decisions, awards, or resolutions of quasi-judicial agencies like the NLRC. The NLRC is a statutory body with a distinct appellate hierarchy; its final judgments are reviewable only by the Supreme Court via a special civil action for certiorari under Rule 65, on grounds of grave abuse of discretion, lack of jurisdiction, or denial of due process. Since petitioners had already availed of, and failed in, that specific Rule 65 remedy before the Supreme Court, they cannot circumvent that process by seeking annulment under Rule 47. The alleged errors in the NLRC decision, including the claim of extrinsic fraud related to the mishandled Supreme Court mail, pertain to the merits or to the proceedings before the Supreme Court itself, not to a void judgment from a regional trial court. Therefore, the Court of Appeals had no jurisdiction to entertain the annulment petition.