G.R. No. 221978 . April 04, 2022.
DMCI PROJECT DEVELOPERS, INC., PETITIONER, VS. NELIA BERNADAS, NOEL BATANES, EDUARDO NONSOL, JOSE BALDE, ELMOR MABATAN, AND LILIO M. REBUENO, RESPONDENTS.

FACTS

The case involves a parcel of land in Taguig City covered by TCT No. 25491 issued to the Lacsina spouses and Renato Dionisio. Respondents Nelia Bernadas, et al., won a labor case against Liberty Transport Corp. and/or Mr. and Mrs. Honorato Lacsina before the NLRC. A Notice of Levy was annotated on the title on March 15, 2006. An auction sale was conducted on April 3, 2009, where Bernadas, et al., emerged as the winning bidder, and a Certificate of Sale was annotated on June 3, 2009. On June 29, 2009, Bernadas, et al., executed a Deed of Sale and/or Certificate of Redemption of Real Property and a Release and Quitclaim in favor of petitioner DMCI Project Developers, Inc., after receiving the sum of P1,915,800.00. Taguig Land Development Corporation later acquired the subject lot and transferred it to DMCI by virtue of a merger. Subsequently, Bernadas, et al., filed a Motion to Nullify the Deed of Sale and Release and Quitclaim before the NLRC, claiming the documents were spurious and falsified, and that they had not been paid their monetary claims. The Labor Arbiter granted the motion, nullifying the documents and ordering the cancellation of TCT No. 12619 (issued to Taguig Land) and the issuance of a new title in favor of complainants. The NLRC affirmed this order. DMCI filed a petition with the Court of Appeals, which was dismissed for being filed out of time. The CA also denied DMCI’s motion for reconsideration. DMCI then filed the present Petition for Review on Certiorari before the Supreme Court.

ISSUE

Whether the Court of Appeals correctly dismissed DMCI’s petition for certiorari for being filed out of time.

RULING

Yes, the Court of Appeals correctly dismissed the petition for being filed out of time. The Supreme Court affirmed the CA’s ruling. The NLRC’s Resolution affirming the Labor Arbiter’s order became final and executory after DMCI failed to file a petition for certiorari with the CA within the 60-day reglementary period. The NLRC issued an Entry of Judgment on July 19, 2011. DMCI received a copy of the NLRC’s denial of its motion for reconsideration on August 29, 2011. It then had only until October 28, 2011, to file the petition. However, DMCI filed its petition with the CA only on November 4, 2011, which was seven days late. The Supreme Court emphasized that procedural rules, particularly those governing the period for appeal, are mandatory and jurisdictional. The failure to file the petition within the prescribed period renders the NLRC’s resolution final and executory, depriving the courts of jurisdiction to alter the final judgment. The Court found no compelling reason to relax the procedural rules in this case. Therefore, the petition was denied.