GR 159024; (January, 2005) (Digest)
G.R. No. 159024; January 14, 2005
LTS PHILIPPINES CORPORATION and JULIE L. EVANGELISTA, petitioners, vs. JOCELYN D. MALIWAT, MA. THERESA ROLLE, MYRA ESTANISLAO and RHODELIA BAUTISTA, respondents.
FACTS
Petitioner LTS Philippines Corporation terminated the employment of the respondents, who were managerial employees, citing serious business losses and a need to reduce personnel. The respondents filed a complaint for illegal dismissal. The Labor Arbiter ruled in their favor, awarding monetary benefits. On appeal, the NLRC modified the decision, ordering the petitioners to pay separation pay instead. The petitioners received the NLRC decision on October 28, 2002, filed a motion for reconsideration on November 7, which was denied via a resolution received by petitioners on January 16, 2003.
The petitioners then filed a petition for certiorari with the Court of Appeals on March 18, 2003, arguing it was filed within 60 days from notice of the NLRC’s November 22, 2002 resolution. The CA dismissed the petition for being filed one day late, computing the last day as March 17, 2003. The petitioners moved for reconsideration, pleading for liberal application of the rules due to their counsel’s heavy workload which allegedly caused an inadvertent error in computing the deadline.
ISSUE
Whether the Court of Appeals erred in dismissing the petition for certiorari for being filed one day beyond the reglementary period.
RULING
The Supreme Court denied the petition, upholding the CA’s dismissal. The Court emphasized that reglementary periods are mandatory and indispensable for the orderly and speedy disposition of cases. The plea for liberal construction was unavailing. The failure of counsel to correctly compute the filing period, attributing it to a heavy workload, constitutes inexcusable negligence. A lawyer has the duty to monitor deadlines and manage their workload to ensure timely filing; the client is bound by this negligence.
The Court further found that the errors ascribed by the petitioners to the NLRC were mere errors of judgment, not jurisdiction, which are not correctible by certiorari. Allowing deviations based on counsel’s workload would lead to endless litigation and undermine the rules designed for judicial efficiency. Thus, the dismissal for tardiness was proper.