G.R. No. 195513 June 22, 2015
MARLON BEDUYA, ROSARIO DUMAS, ALEX LEONOZA, RAMILO FAJARDO, HARLAN LEONOZA, ALVIN ABUYOT, DINDO URSABIA, BERNIE BESONA, ROMEO ONANAD, ARMANDO LIPORADA, FRANKFER ODULIO, MARCELO MATA, ALEX COLOCADO, JOJO PACATANG, RANDY GENODIA and ISABINO B. ALARMA, JR., Petitioners, vs. ACE PROMOTION AND MARKETING CORPORATION and GLEN HERNANDEZ, Respondents.

FACTS

Respondent Ace Promotion and Marketing Corporation (APMC) is a contractor engaged in deploying workers for promotional and merchandising services. It entered into a Promotional Contract with Delfi Marketing, Inc. (Delfi) and employed petitioners as merchandisers under fixed-term employment contracts, the last of which were until January 30, 2007. Delfi notified APMC that their contract would expire on January 31, 2007, and APMC informed petitioners that their last day of work would be January 30, 2007. Petitioners filed complaints for illegal dismissal and money claims before the Labor Arbiter, alleging they were regular employees of APMC since 1997 and that the expiration of the APMC-Delfi contract did not justify their dismissal. The Labor Arbiter ruled in favor of petitioners, declaring them illegally dismissed and awarding reinstatement, backwages, unpaid wages, ECOLA, damages, and attorney’s fees. Respondents appealed to the NLRC, filing a Memorandum of Appeal with a Motion for Reduction of Bond and posting a supersedeas bond of ₱437,210.00. Petitioners opposed the appeal, arguing the bond was insufficient relative to the total monetary award of ₱6,269,856.89, thus the appeal was not perfected and the Labor Arbiter’s decision had become final. The NLRC, without resolving the motion for bond reduction, reversed the Labor Arbiter, finding petitioners were contractual employees whose employment legally ended with the project, and dismissed the illegal dismissal complaint but affirmed the awards for unpaid wages and ECOLA. The Court of Appeals affirmed the NLRC, finding respondents acted in good faith and that petitioners were not illegally dismissed. Petitioners elevated the case to the Supreme Court.

ISSUE

The primary issues were: (1) Whether the filing of an appeal with a motion to reduce the appeal bond tolls the period to perfect an appeal; (2) Whether an appeal bond of ₱437,210.00 is reasonable relative to a possible monetary award of ₱6,269,856.89; (3) Whether the Labor Arbiter’s decision is deemed final and executory if the appeal was not perfected; and (4) Whether it is procedurally correct to render judgment when a pending motion (for bond reduction) remains unresolved.

RULING

The Supreme Court denied the petition and affirmed the CA and NLRC decisions. The Court held that procedural rules may be relaxed in labor cases to serve substantial justice. While the appeal bond was initially insufficient, respondents demonstrated willingness and good faith by posting a bond and filing a motion for its reduction, which constitutes substantial compliance. The Court agreed with the NLRC’s factual finding that petitioners were project employees hired under fixed-term contracts for a specific undertaking (Delfi), and their employment legally terminated upon the project’s completion, constituting a lawful dismissal. The NLRC did not commit grave abuse of discretion in deciding the appeal without first resolving the motion for bond reduction, as the motion was deemed submitted for resolution, and its merits were effectively passed upon in the decision. The awards for unpaid wages and ECOLA were affirmed.