G.R. No. 190654, July 28, 2020
KARJ GLOBAL MARKETING NETWORK, INC., Petitioner, vs. MIGUEL P. MARA, Respondent.

FACTS

Respondent Miguel P. Mara filed a complaint before the Labor Arbiter against petitioner Karj Global Marketing Network, Inc. for non-payment of 14th month pay and refund of his car’s maintenance expenditures, damages, and attorney’s fees. He alleged that based on an Offer Sheet, he was entitled to a “retention incentive 14th month bonus” and that petitioner undertook to provide him with a car and shoulder its repairs and maintenance costs. Petitioner contested the claims, arguing the 14th month bonus was discretionary and that respondent’s car reimbursement claim did not comply with the company car policy. The Labor Arbiter ruled in favor of respondent, ordering petitioner to pay P198,800.00 as 14th month pay for 2004 and 2005 and to refund P289,000.00 as company car maintenance costs. Petitioner appealed to the NLRC but failed to post the required appeal bond. Petitioner argued it was barred from posting the bond due to an Order from the Regional Trial Court (RTC) in an involuntary insolvency case filed against it, which enjoined it from disposing of its property except for ordinary business operations. The NLRC dismissed the appeal for non-perfection due to the lack of an appeal bond. The Court of Appeals affirmed the NLRC, ruling the appeal bond was an indispensable requirement. Petitioner elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals was correct in affirming the NLRC’s strict adherence to the requirement for the posting of an appeal bond to perfect an appeal.

RULING

No. The Supreme Court granted the Petition. It ruled that the existence of the insolvency proceedings constituted an exceptional circumstance warranting the liberal application of the rules requiring an appeal bond. The purpose of the bond is to ensure the employee receives the monetary award if he prevails. Here, the failure to file the bond did not contradict this purpose given the insolvency context. The NLRC, mandated to act with justice, reason, and equity, should have allowed the appeal and ruled on the merits. The Supreme Court proceeded to rule on the merits of the case. It found that respondent failed to prove his entitlement to the 14th month pay, as the Offer Sheet he presented was not signed by an authorized company representative and appeared to be a forgery. It also found that respondent failed to submit any document to prove his entitlement to car maintenance reimbursements. Consequently, the Court dismissed respondent’s complaint for lack of merit. The CA Decision and Resolution were reversed and set aside.