G.R. No. 203642, January 27, 2016
Thomasites Center for International Studies (TCIS), Petitioner, vs. Ruth N. Rodriguez, Irene P. Padrigon and Arlyn B. Rillera, Respondents.

FACTS

Respondents, licensed teachers, were hired by TCIS through its Academic Dean, Dr. Cheol Je Cho, to develop academic programs and perform other foundational tasks. They were promised a monthly salary but were terminated shortly after classes began in December 2004, following a threat of resignation from American teachers. The termination letters, signed by Dr. Cho, cited company restructuring. The respondents filed complaints for illegal dismissal. Summons and notices for the labor case were served upon Dr. Cho at TCIS’s address. TCIS did not file a position paper, but its counsel attended several hearings before the Labor Arbiter (LA).
The LA ruled in favor of the respondents, finding illegal dismissal. TCIS, through new counsel, filed a petition for relief from judgment with the NLRC, arguing it was denied due process as summons were improperly served on Dr. Cho and it was deprived of the chance to file its position paper. The NLRC denied the petition, ruling TCIS had other adequate remedies and failed to prove excusable negligence. TCIS then filed a petition for certiorari with the Court of Appeals (CA), which dismissed it outright for procedural defects, including failure to indicate material dates and to attach necessary documents.

ISSUE

Whether the CA correctly dismissed TCIS’s petition for certiorari and whether the NLRC correctly denied its petition for relief from judgment, thereby upholding the finding of illegal dismissal.

RULING

The Supreme Court denied TCIS’s petition, affirming the CA and NLRC rulings. On procedure, the Court held that while technical rules are relaxed in labor cases, this does not justify a blatant disregard of procedural requirements. The CA’s dismissal for TCIS’s failure to comply with the basic requisites of a petition for certiorari under Rule 65, such as indicating material dates and submitting essential annexes, was proper. The Court distinguished this case from precedents where subsequent submission cured minor defects, as TCIS’s omissions were fundamental to determining the petition’s timeliness and merit.
On the substantive issue of due process, the Court found no merit in TCIS’s claim. Service of summons on Dr. Cho, a responsible officer who hired and terminated the respondents, at TCIS’s address was valid and binding on the corporation. Furthermore, TCIS’s initial counsel attended LA hearings, proving it was notified of the proceedings. Its failure to file a position paper was due to its own negligence, not a denial of due process. The NLRC correctly denied the petition for relief, as TCIS failed to demonstrate the fraud, accident, mistake, or excusable negligence required for such an extraordinary remedy. Consequently, the LA’s finding of illegal dismissal, which TCIS did not timely appeal, stands.