G.R. No. 188492 , August 28, 2018
Guagua National Colleges, Petitioner, vs. Court of Appeals, GNC Faculty and Labor Union and GNC Nonteaching Maintenance Labor Union, Respondents.

FACTS

The dispute originated from the allocation of tuition fee increases under Republic Act No. 6728 . Petitioner Guagua National Colleges (GNC) applied a 7% tuition fee hike for school year 2006-2007 and decided to use 70% of the incremental proceeds to fund its retirement plan. Respondents, the faculty and non-teaching unions, contested this action, arguing it violated the law requiring that the 70% share be allocated for salaries, wages, allowances, and other benefits of personnel. The parties submitted the case to voluntary arbitration.
Voluntary Arbitrator Froilan M. Bacungan rendered a decision on June 16, 2008, ruling in favor of GNC, holding that retirement benefits constituted “other benefits” chargeable against the 70% fund. The respondents received the decision on June 16, 2008. On June 30, 2008, they filed an Urgent Motion for Extension with the Court of Appeals (CA), seeking an additional 15 days to file a petition for review. The CA granted the motion. The respondents filed their petition for review on July 16, 2008. GNC moved to dismiss the petition, arguing it was filed out of time.

ISSUE

Whether the Court of Appeals acted without or in excess of its jurisdiction in taking cognizance of the petition for review, considering the petitioner’s claim that the voluntary arbitrator’s decision had already become final and executory.

RULING

The Supreme Court ruled that the Court of Appeals correctly assumed jurisdiction. The petition for review was filed within the reglementary period. The core legal conflict was the applicable appeal period from a voluntary arbitrator’s decision: 10 days under Article 276 of the Labor Code or 15 days under Rule 43 of the Rules of Court. The Court resolved this conflict in favor of the 15-day period under Rule 43.
The Court harmonized the provisions by holding that while Article 276 of the Labor Code provides for a 10-day period for the decision to become final, the specific mode of appeal to the Court of Appeals is governed by Rule 43, which prescribes a 15-day period from notice of the decision. This interpretation is consistent with the Court’s ruling in Manila Midtown Hotels & Land Corp. v. Borromeo and the principle that procedural rules should be liberally construed, especially in labor cases, to ensure the resolution of substantive rights. The earlier case of *Coca-Cola Bottlers Philippines, Inc. Sales Force Union-PTGWO-Balais v. Coca-Cola Bottlers Philippines, Inc.*, which mentioned a 10-day period, was clarified as not establishing a categorical rule conflicting with the 15-day period under Rule 43.
Therefore, the respondents’ filing of their petition for review on July 16, 2008, was timely, having been filed within 15 days from June 30, 2008 (the date of their motion for extension, which was within the initial 15-day period from receipt of the decision on June 16). The CA did not commit grave abuse of discretion in denying the motion to dismiss. The petition was dismissed.