GR 156379; (September, 2005) (Digest)
G.R. No. 156379 September 16, 2005
Emma Cordova, Ginaly Arnuza, Lerma Plazon, Joann Gamil, Teresita Torion and Nene Janiola, Petitioners, vs. Keysa’s Boutique and/or Sps. Cris and Eleanor Albaran, Respondents.
FACTS
Petitioners, salesgirls of Keysa’s Boutique, were dismissed after requesting a salary increase to meet the minimum wage and payment of their 13th-month pay. They filed a complaint for illegal dismissal and monetary claims. The Labor Arbiter ruled in their favor, awarding ₱384,352.15. Respondents failed to file a position paper. They appealed to the NLRC, pleading for a reduction of the required appeal bond due to alleged financial distress. They submitted a bank certification showing a balance of ₱23,008.19 and later a Deed of Assignment for ₱50,000, but never posted the full cash bond equivalent to the monetary award.
The NLRC granted the reduction and admitted the appeal, eventually setting aside the Labor Arbiter’s decision and remanding the case. This NLRC decision was affirmed by the Court of Appeals. Petitioners elevated the case to the Supreme Court via certiorari, arguing that the NLRC acquired no jurisdiction over the appeal due to respondents’ failure to post the proper appeal bond.
ISSUE
Whether the National Labor Relations Commission (NLRC) acquired jurisdiction over the respondents’ appeal from the Labor Arbiter’s decision despite their failure to post the required appeal bond.
RULING
No. The NLRC did not acquire jurisdiction. The posting of a cash or surety bond equivalent to the monetary award is a mandatory requirement for the perfection of an appeal in labor cases, as provided under the NLRC Rules of Procedure. This requirement is jurisdictional; non-compliance renders the Labor Arbiter’s decision final and executory. The Court found no merit in respondents’ plea for bond reduction. Their claim of financial hardship was not substantiated by clear and convincing evidence, as the bank certification and Deed of Assignment did not conclusively prove an inability to pay. The bond serves the crucial purpose of ensuring that the award will be preserved in case the appeal is dismissed. Allowing an appeal without the requisite bond on unsubstantiated grounds would defeat this purpose. Consequently, the NLRC acted without jurisdiction in entertaining the appeal and modifying the Labor Arbiter’s decision. The Supreme Court reinstated the Labor Arbiter’s original decision awarding the monetary claims to the petitioners.