GR 188514; (August, 2013) (Digest)
G.R. No. 188514; August 28, 2013
MARIA LOURDES D. CASTELLS and SHALIMAR CENTI-MANDANAS, Petitioners, vs. SAUDI ARABIAN AIRLINES, Respondent.
FACTS
Petitioners, flight attendants for Saudi Arabian Airlines (SAUDIA), were among those issued a transfer order from Manila to Jeddah. Centi-Mandanas complied but was later pressured to sign a pre-typed resignation letter. Castells did not comply with the transfer and was instructed to amend her resignation letter to state it was voluntary. They filed an illegal dismissal complaint. The Labor Arbiter ruled in their favor, but the NLRC reversed, finding the resignations voluntary and noting they had executed a release undertaking. Petitioners’ motion for reconsideration was denied by the NLRC on October 26, 2007.
Petitioners filed a Motion for Extension to File a Petition for Certiorari with the Court of Appeals on January 16, 2008, which was granted. They filed the petition on February 4, 2008. SAUDIA moved for reconsideration, arguing that A.M. No. 07-7-12-SC, effective December 27, 2007, had abolished extensions of time to file such petitions. The CA granted SAUDIA’s motion, deemed the petition not admitted for being filed out of time, and dismissed the case.
ISSUE
Whether the Court of Appeals correctly refused to admit the petition for certiorari for being filed out of time due to the amendments introduced by A.M. No. 07-7-12-SC.
RULING
The Supreme Court ruled in favor of the petitioners, setting aside the CA’s resolutions. The Court held that the CA erred in applying A.M. No. 07-7-12-SC retroactively to the petitioners’ case. The Court emphasized that procedural rules regulating the procedure for filing appeals are generally prospective in application. The NLRC denied the motion for reconsideration on October 26, 2007, and the new rule took effect on December 27, 2007. At the time the petitioners’ right to appeal accrued upon the denial of their motion for reconsideration, the prevailing rule still allowed the filing of a motion for extension, as established in previous jurisprudence. The petitioners timely filed their motion for extension on January 16, 2008, within the reglementary period under the old rule. Therefore, they were entitled to the extension granted by the CA. The subsequent rule disallowing extensions could not be applied to impair a vested right that had already accrued. The case was remanded to the CA for resolution on the merits.