G.R. No. 244374 . February 15, 2022
Puregold Price Club, Inc., Petitioner, vs. Court of Appeals and Renato M. Cruz, Jr., Respondents.

FACTS

Renato M. Cruz, Jr. was hired by Puregold Price Club, Inc. (PPCI) and later appointed as store manager at Puregold Extra Ampid. His duties included activating and deactivating the Intruder Alarm System (IAS). On March 16, 2015, the IAS sounded alarms, but Renato did not respond. He later took four plastic pails from the store for personal use. Following an administrative process, PPCI terminated Renato for gross neglect of duty and stealing. Renato filed a complaint for illegal dismissal before the Labor Arbiter (LA), impleading “Puregold Extra” and two individuals as respondents. Notices for the Single Entry Approach (SEnA) conciliation were sent to Puregold Extra’s address in San Mateo, Rizal, and PPCI’s HR Manager and counsel attended these conferences. The LA rendered a decision in favor of Renato, based solely on his position paper as the named respondents failed to appear. PPCI moved to annul the decision, claiming it was not properly impleaded and did not receive summons. The NLRC granted PPCI’s petition and remanded the case to the LA for proper proceedings due to improper service of summons. Renato filed a petition for certiorari with the Court of Appeals (CA) on March 13, 2017, stating he received the NLRC’s denial of his motion for reconsideration on January 12, 2017. The CA granted Renato’s petition, annulled the NLRC resolutions, and declared the LA’s initial decision final and executory. PPCI moved for reconsideration, which was denied. PPCI received the CA’s denial on February 13, 2019, and had until February 28, 2019, to file a petition for review. PPCI moved for a 30-day extension until March 30, 2019, but instead filed a petition for certiorari on March 15, 2019.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in giving due course to Renato’s petition for certiorari despite it being filed beyond the 60-day reglementary period.

RULING

The Supreme Court granted PPCI’s petition and reversed the CA’s decision. The Court held that Renato’s petition for certiorari before the CA was filed out of time. The 60-day period to file such a petition is mandatory and jurisdictional. Renato received the NLRC Resolution denying his motion for reconsideration on January 12, 2017. Therefore, he had until March 13, 2017, to file his petition. While he filed it on March 13, 2017, this date was beyond the 60-day period as computed from January 12, 2017. The CA erred in not dismissing the petition for being time-barred. Procedural rules are not mere technicalities and must be strictly followed to ensure order and efficiency in the judicial system. The recognized exceptions to the strict application of the period rule were not present in this case. Consequently, the NLRC Resolutions dated September 8, 2016, and October 28, 2016, which remanded the case to the LA, stand. The LA’s subsequent decision on remand, which found Renato’s dismissal valid, had already become final and executory.