G.R. No. 187491 July 8, 2015
FAR EAST BANK AND TRUST COMPANY, Petitioner, vs. LILIA S. CHUA, Respondent.

FACTS

Respondent Lilia S. Chua, an Assistant Vice President of petitioner Far East Bank and Trust Co., was dismissed on July 1, 1999, after the bank found she engaged in multiple fraudulent kiting transactions. Chua filed an illegal dismissal complaint. The Labor Arbiter ruled in her favor, declaring the dismissal illegal and awarding reinstatement and backwages. Petitioner Far East Bank failed to timely file its Position Paper before the Labor Arbiter despite an extension. On the same date the Labor Arbiter’s Decision was rendered (April 25, 2000), Far East Bank filed a Motion to admit its Position Paper, which was denied on May 15, 2000. On May 25, 2000, Far East Bank directly filed its Notice of Appeal and Memorandum of Appeal before the National Labor Relations Commission (NLRC), not with the Regional Arbitration Branch that rendered the decision. The NLRC reversed the Labor Arbiter’s ruling. Chua filed a Motion for Reconsideration with the NLRC, which was denied. Chua then filed a Petition for Certiorari before the Court of Appeals, arguing for the first time that the NLRC should not have entertained the appeal because it was not perfected due to direct filing with the NLRC instead of the Regional Arbitration Branch. The Court of Appeals granted Chua’s petition, declared the NLRC Resolutions null and void, and reinstated the Labor Arbiter’s Decision, ruling that the direct filing meant no appeal was perfected and the Labor Arbiter’s Decision had attained finality.

ISSUE

Whether Executive Labor Arbiter Quintin B. Cueto III’s April 25, 2000 Decision attained finality in light of petitioner Far East Bank and Trust Co.’s direct filing of its appeal before the National Labor Relations Commission, rather than before the Regional Arbitration Branch XII, Cotabato City.

RULING

No. The Supreme Court reversed the Court of Appeals and reinstated the NLRC Resolutions. The Court held that while the issue of jurisdiction may be raised at any time, a party may be barred by estoppel or laches. Chua voluntarily participated in the appeal proceedings before the NLRC by filing a Motion for Reconsideration and arguing the merits of the case. She failed to raise the issue of improper venue of the appeal during the NLRC proceedings. By actively seeking affirmative relief from the NLRC without questioning its jurisdiction, Chua is estopped from belatedly raising the issue of jurisdiction in her certiorari petition before the Court of Appeals. A mere procedural lapse in the venue of filing the appeal memorandum is not fatal, especially in labor cases where technicalities yield to substantial justice. The NLRC acted within its discretion in admitting the appeal.