G.R. No. 206612 , August 17, 2015.
Toyota Alabang, Inc., Petitioner, vs. Edwin Games, Respondent.

FACTS

Respondent Edwin Games, a foreman for petitioner Toyota Alabang, Inc., was charged with qualified theft for allegedly stealing vehicle lubricants. Two years later, on August 24, 2007, Games filed a complaint for illegal dismissal, nonpayment of benefits, and damages. Petitioner, through counsel, failed to file its required Position Paper by the set date of November 15, 2007. After several resettings, petitioner failed to appear at a January 11, 2008 hearing and did not submit its pleading. Consequently, the Labor Arbiter (LA) declared the case submitted for decision. On February 5, 2008, the LA ruled that Games was illegally dismissed and ordered petitioner to pay him monetary awards totaling P535,553.07. Petitioner did not file a motion for reconsideration, making the LA’s decision final and executory. Upon issuance of a Writ of Execution, petitioner sought to quash it and reopen the proceedings, citing counsel’s negligence. The LA denied this. Petitioner appealed to the NLRC, which denied due course to the appeal because petitioner failed to comply with the appeal bond requirement under the NLRC Rules, specifically by not providing proof of a security deposit or collateral. The NLRC also ruled that no appeal may be taken from an order of execution of a final judgment. The Court of Appeals (CA) affirmed the NLRC, finding no grave abuse of discretion. Petitioner then filed a Petition for Review on Certiorari with this Court, which was initially denied via a minute resolution, prompting the instant Motion for Reconsideration.

ISSUE

Whether the Court of Appeals committed a reversible error in refusing to reopen the proceedings before the Labor Arbiter, thereby upholding the denial of petitioner’s appeal for failure to perfect an appeal bond and due to the finality of the LA’s decision.

RULING

The Court, through Chief Justice Sereno, denied the Motion for Reconsideration and upheld the CA’s ruling. The Court held that the CA correctly refused to reopen the proceedings. The LA’s decision had become final and executory due to petitioner’s failure to file a timely appeal. Reopening a case is an extraordinary remedy requiring good cause, which petitioner failed to show. The Court found petitioner itself negligent: it was informed of the need to file a Position Paper but failed to do so, failed to attend hearings, and did not move to file its pleading before the LA resolved the case. Petitioner’s own lack of vigilance precluded a claim of denial of due process. On the specific procedural issues, the Court ruled that: (1) the appeal bond requirement under Article 223 of the Labor Code and the NLRC Rules applies generally whenever the LA’s decision involves a monetary award, and is not limited to certain types of rulings; (2) the NLRC did not err in requiring proof of a security deposit for the bond, as the bonding company’s mere certification was insufficient; and (3) the NLRC correctly held that no appeal lies from an order of execution of a final judgment. The Court emphasized that its review in a Rule 45 petition is limited to determining whether the CA correctly found that the NLRC committed no grave abuse of discretion, which was not present here. The dissenting opinion of Justice Bersamin, which advocated for remanding the case to the LA for reception of evidence, was not adopted.