GR 199384; (September, 2015) (Digest)
G.R. No. 199384, September 09, 2015
LE SOLEIL INT’L. LOGISTICS CO., INC., AND/OR BETH UMALI, REYNANTE MALABANAN, AND EUGENIO S. YNION, JR., PETITIONERS, VS. VICENTE SANCHEZ, DAVID R. CONDE, AND NATIONAL LABOR RELATIONS COMMISSION, RESPONDENTS.
FACTS
Petitioners filed a Petition for Certiorari with the Court of Appeals (CA) seeking to nullify the National Labor Relations Commission (NLRC) Decision dated April 25, 2011, and its Resolution dated June 14, 2011. The CA dismissed the petition outright in a Resolution dated September 16, 2011, on three grounds: (1) the petition was filed three days late, having been filed on September 5, 2011, instead of the deadline of September 2, 2011 (the 60-day reglementary period from notice of the denial of their motion for reconsideration on July 24, 2011); (2) the petition lacked a statement of specific material dates as required by the rules; and (3) the petition did not state the date of issue of counsel’s Mandatory Continuing Legal Education (MCLE) Certificate of Compliance. The CA denied petitioners’ motion for reconsideration in a Resolution dated November 17, 2011. Petitioners then elevated the case to the Supreme Court via a Petition for Review on Certiorari, arguing that the CA erred in not exercising its equity jurisdiction and in not finding that the NLRC gravely abused its discretion.
ISSUE
Whether the Court of Appeals erred in dismissing the Petition for Certiorari for being filed out of time and for procedural deficiencies.
RULING
The Supreme Court denied the petition and affirmed the assailed CA Resolutions. The Court ruled that the perfection of an appeal within the reglementary period is mandatory and jurisdictional. Under Section 4, Rule 65 of the Rules of Court, a petition for certiorari must be filed strictly within 60 days from notice of the judgment or resolution. The 60-day period is inextendible. Petitioners conceded that their filing was three days late. The Court found no compelling reason to liberally apply the rules in this case, as petitioners failed to advance a reasonable or meritorious explanation for their failure to comply. Procedural rules, especially those on reglementary periods, are strictly applied to prevent needless delays and ensure the orderly discharge of judicial business. The timeliness of filing is a jurisdictional requirement.