GR 181516; (August, 2009) (Digest)
G.R. No. 181516 ; August 19, 2009
Cesario L. Del Rosario, Petitioner, vs. Philippine Journalists, Inc., Respondent.
FACTS
Petitioner Cesario L. del Rosario filed a complaint for illegal dismissal with money claims against respondent Philippine Journalists, Inc. (PJI). The Labor Arbiter ruled in del Rosario’s favor, ordering PJI to pay substantial monetary awards. PJI appealed to the National Labor Relations Commission (NLRC), posting an appeal bond issued by Philippine Pryce Assurance Corporation (PPAC) on January 2, 2003. The NLRC initially dismissed the appeal, finding it unperfected because PPAC was allegedly not an accredited bonding company at the time the bond was posted, based on a certification from the Office of the Court Administrator. The NLRC later granted PJI a chance to post a new bond but ultimately dismissed the appeal for failure to comply.
PJI elevated the matter to the Court of Appeals via a petition for certiorari. The CA reversed the NLRC, finding that at the time PJI obtained the surety bond on January 2, 2003, PPAC was still duly accredited and authorized to issue such bonds. The CA noted that the Supreme Court’s blacklisting of PPAC occurred later, in October 2003. Thus, the CA directed the NLRC to admit the appeal and decide it on the merits, ordering PJI to replace the bond with one from a currently accredited company. Del Rosario’s motion for reconsideration was denied, prompting this petition.
ISSUE
Whether the Court of Appeals erred in setting aside the NLRC’s dismissal of PJI’s appeal and in ordering the NLRC to admit the appeal on the merits.
RULING
The Supreme Court denied the petition and affirmed the CA’s decision. The Court held that the NLRC committed grave abuse of discretion in dismissing the appeal based on an invalid bond. The legal requirement under Article 223 of the Labor Code and the NLRC Rules is that an appeal bond must be issued by a reputable bonding company duly accredited by the Commission. The core factual finding of the CA, which the Supreme Court upheld, was that PPAC was still an accredited surety when it issued the bond on January 2, 2003. The subsequent cancellation of its accreditation months later did not retroactively invalidate a bond lawfully issued at a time when the company was in good standing.
The Court emphasized that technicalities should not frustrate substantive justice, especially in labor cases where the policy is to resolve disputes on their merits. The dismissal of an appeal based on a procedural defect that did not exist at the time of filing is unjust. However, to protect del Rosario’s rights stemming from the monetary award, the Court affirmed the CA’s directive for PJI to post a new bond from a currently accredited company as a condition for the appeal to proceed. The NLRC was ordered to give due course to the appeal and decide the case on its merits with dispatch upon PJI’s compliance.