G.R. No. L-29770 July 19, 1973
PHILIPPINE FIBER PROCESSING COMPANY, INC., petitioner, vs. COURT OF INDUSTRIAL RELATIONS AND PHILFIBCO EMPLOYEES AND LABORERS UNION, LOCAL 106, (NWB), respondents.
FACTS
The respondent union filed an unfair labor practice complaint against petitioner company in 1956. After protracted hearings, the Court of Industrial Relations (CIR) rendered a decision on May 17, 1968, ordering the reinstatement of union members with three years of back wages. Petitioner received the decision on May 21, 1968. On May 24, 1968, petitioner filed a motion for extension of time to file a motion for reconsideration, citing counsel’s preoccupation with other cases and the voluminous records. The CIR, citing its standing “no-extension” policy, denied this motion on May 25, 1968. Petitioner nonetheless filed its motion for reconsideration on May 30, 1968. The CIR subsequently dismissed this motion for having been filed beyond the five-day reglementary period prescribed by its rules.
ISSUE
The primary issue is whether the filing of a motion for extension of time to file a motion for reconsideration tolls the running of the reglementary period for filing such a motion under CIR rules.
RULING
The Supreme Court ruled that the period was not tolled. The Court affirmed the CIR’s dismissal of the motion for reconsideration as filed out of time. The legal logic is anchored on established jurisprudence, particularly the ruling in King vs. Joe, which holds that a petition for extension of time does not, by itself, interrupt the period fixed for perfecting an appeal or filing a requisite motion. The rationale is to prevent an absurdity where a last-minute motion for extension would automatically extend the deadline. The Court upheld the CIR’s strict “no-extension” policy regarding motions for reconsideration under its Rules 15 and 16, a policy repeatedly sustained in prior cases. The Court found petitioner’s reasons for seeking an extension unmeritorious, noting its counsel had been involved in the case since 1960 and thus had ample time to familiarize himself with the records. On the substantive merits, the Supreme Court, after a thorough review, found the CIR’s decision supported by substantial evidence. It agreed with the CIR’s factual findings that while the company did not commit an unfair labor practice by refusing to bargain (due to a legitimate doubt regarding majority representation), it did illegally lock out union members. The award of reinstatement and back wages was thus affirmed, subject to the deduction of interim earnings. The appeal was dismissed.