GR 191215; (February, 2014) (Digest)
G.R. No. 191215 ; February 3, 2014
THENAMARIS PHILIPPINES, INC./OCEANIC NAVIGATION LTD. and NICANOR B. ALTARES, Petitioners, vs. COURT OF APPEALS and AMANDA C. MENDIGORIN, Respondents.
FACTS
This case originated from a labor claim filed by Amanda Mendigorin, widow of seafarer Guillermo Mendigorin, for death benefits after her husband died of colon cancer during his employment with Thenamaris. The Labor Arbiter ruled in her favor, but the National Labor Relations Commission (NLRC) reversed this decision. Mendigorin received the NLRC’s denial of her motion for reconsideration on July 8, 2009, giving her until September 6, 2009 (extended to September 7 as the 6th was a Sunday) to file a petition for certiorari under Rule 65 with the Court of Appeals. On September 8, 2009, she filed a Motion for Extension of Time, and subsequently filed her Petition for Certiorari on September 22, 2009, which was 15 days beyond the original deadline.
The Court of Appeals, in a Resolution dated November 20, 2009, noted the late filing and procedural deficiencies in the petition. However, citing the interest of substantial justice, it entertained the petition and directed Mendigorin to cure the technical flaws. The petitioners moved for reconsideration, arguing that the Motion for Extension was a prohibited pleading and that the petition, having been filed out of time, was a mere scrap of paper, rendering the NLRC decision final.
ISSUE
Whether the Court of Appeals committed grave abuse of discretion in entertaining the Petition for Certiorari despite its late filing and in granting an extension of time to file the same.
RULING
The Supreme Court ruled that the Court of Appeals did not commit grave abuse of discretion. The legal logic centers on the proper interpretation of the 60-day reglementary period for filing a petition for certiorari under Rule 65, as amended by A.M. No. 07-7-12-SC. The amendment made the period “non-extendible,” but this strictness is not absolute. Jurisprudence establishes that while extensions are generally prohibited, they may be granted in highly meritorious cases to serve the demands of substantial justice and avoid a miscarriage thereof.
The Court found that Mendigorin’s Motion for Extension, filed on September 8, was technically filed one day late from the September 7 deadline. However, the delay was minimal. More critically, the underlying labor case involved a substantial claim for death benefits of a seafazer who served the company for 27 years, raising a potentially meritorious issue concerning the compensability of his illness. Dismissing the petition purely on this technical ground would result in a permanent foreclosure of judicial review on the merits. The Court of Appeals, therefore, acted within its sound discretion in relaxing the procedural rules to allow a full hearing on the substantive rights of the parties. The paramount policy of deciding cases on their merits overrides strict procedural adherence, especially where no intent to delay is apparent and a compelling reason exists.