G.R. No. 164333 ; August 24, 2007
LYNX INDUSTRIES CONTRACTOR, INC., et al., Petitioners, vs. EUSTERIO T. TALA, et al., Respondents.

FACTS

Private respondents Eusterio Tala and Leonito Viagedor were employees of petitioner Lynx Industries Contractor, Inc. The company ceased operations in November 2000, leading to the termination of their employment. They filed complaints for illegal dismissal and monetary claims. In a Decision dated March 8, 2002, Labor Arbiter Nieves De Castro ruled in favor of the employees, ordering petitioners to pay backwages, separation pay, and other benefits. The decision became final and executory as neither party appealed within the reglementary period. A writ of execution was subsequently issued.
On July 9, 2002, petitioners filed a petition for relief from judgment with the NLRC, seeking to set aside the Labor Arbiter’s decision. They argued their failure to appeal was due to their former counsel’s negligence and that the decision contained substantive errors. The NLRC dismissed the petition, finding it was filed one day beyond the 60-day period from their counsel’s receipt of the decision on May 9, 2002. The Court of Appeals affirmed this dismissal.

ISSUE

Did the Court of Appeals err in affirming the dismissal of the petition for relief from judgment for being filed one day late?

RULING

No, the Court of Appeals did not err. The Supreme Court denied the petition, emphasizing the mandatory nature of procedural rules on reglementary periods. A petition for relief from judgment under Rule 38 of the Rules of Court must be filed within sixty (60) days from knowledge of the judgment and not more than six (6) months from its entry. These periods are strictly construed and are indispensable for the finality of judgments.
The Court found petitioners’ computation incorrect. Since their counsel received the decision on May 9, 2002, the 60-day period to file the petition for relief expired on July 8, 2002. Their filing on July 9, 2002, was indisputably one day late. The Court rejected the argument that counsel’s negligence warranted relaxation of the rules. For negligence to be excusable, it must be so gross that the client is deprived of due process. Petitioners failed to demonstrate this; they were given an opportunity to present their case before the Labor Arbiter. The law favors the vigilant, not those who sleep on their rights. The tardiness of one day, absent a compelling justification, was fatal to their petition. The subsequent substantive arguments raised by petitioners were correctly deemed moot by the appellate court, as the petition was already time-barred.