GR 154284; (October, 2006) (Digest)
G.R. No. 154284 , October 27, 2006
BIBIANA FARMS & MILLS, INC., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION (5th Division) and ROGELIO MAJASOL, respondents.
FACTS
Petitioner Bibiana Farms & Mills, Inc. terminated Rogelio Majasol, an assistant department head, after he was caught attempting to leave company premises with a container of feeds. Following an internal inquiry and a failed settlement conference at the DOLE, Majasol was dismissed for loss of trust and confidence. The Labor Arbiter initially dismissed Majasol’s complaint for illegal dismissal, a decision later reversed by the NLRC, which found the dismissal illegal and lacking in due process. Upon petitioner’s motion for reconsideration, the NLRC reinstated the Labor Arbiter’s finding of legal dismissal.
Majasol filed a special civil action for certiorari with the Court of Appeals. The CA initially dismissed his petition for failure to pay the required docket fees within the reglementary period. However, upon Majasol’s motion for reconsideration, the CA granted relief and reinstated the petition. Bibiana Farms assailed this CA Resolution via the instant Petition for Certiorari, arguing the CA committed grave abuse of discretion in relaxing the rule on mandatory payment of docket fees.
ISSUE
Whether the Court of Appeals committed grave abuse of discretion in reinstating Rogelio Majasol’s petition despite his failure to pay docket fees on time.
RULING
The Supreme Court ruled that the Court of Appeals did not commit grave abuse of discretion. While payment of docket fees within the prescribed period is generally mandatory and jurisdictional, the Court has consistently allowed exceptions based on equitable grounds to serve substantial justice. The rule, while strict, is not absolute and may be relaxed under compelling circumstances to prevent a miscarriage of justice, particularly where the appeal raises meritorious issues.
In this case, the CA’s exercise of discretion to admit the belated payment was justified. The right to appeal is an essential part of the judicial system, and courts should afford litigants the amplest opportunity for a just disposition of their cause, free from the constraints of mere technicalities. The Court found no capricious or whimsical exercise of judgment by the CA warranting corrective action via certiorari. Consequently, the Supreme Court dismissed the petition and remanded the case to the CA for continuation of proceedings on the substantive merits of the illegal dismissal case.