G.R. No. L-39686 June 25, 1980
VOLKSCHEL LABOR UNION, MARIANO SUAREZ, PEDRO TORRES, JAIME RAMOS and ANTONIO GALAN, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION and PEOPLE’S CAR, INCORPORATED, respondents.

FACTS

Petitioner Volkschel Labor Union filed an unfair labor practice complaint against respondent People’s Car, Inc., alleging unjust transfers and suspension of unionists, violation of the collective bargaining agreement (CBA), and refusal to negotiate in good faith. The company, citing a business slump at its Malabon District Office, implemented a retrenchment program and ordered the transfer of several employees to its Cebu District and a sister corporation. The affected employees refused the transfer, leading to their indefinite suspension. The union argued the transfer moved employees outside the bargaining unit defined in the CBA as the “Greater Manila Area.” The company defended its action as a management prerogative under the CBA and a necessary business decision, offering employees options including transfer, temporary layoff, or separation pay.
Pending the complaint, the company reinstated two employees but dismissed petitioners Mariano Suarez, Jaime Ramos, Pedro Torres, and Antonio Galan for insubordination. The labor arbitrator rendered an award on February 1, 1974, ordering the reinstatement of the four dismissed employees with full backwages and directing the company to comply with the CBA’s agency fee clause. The company appealed this award to the National Labor Relations Commission (NLRC).

ISSUE

Whether the appeal filed by the respondent company with the NLRC from the arbitrator’s award was perfected within the reglementary period, thereby vesting the NLRC with jurisdiction to modify the award.

RULING

No. The Supreme Court reinstated the arbitrator’s award, ruling that the NLRC decision modifying it was void for lack of jurisdiction due to an untimely appeal. The Court emphasized that the perfection of an appeal within the statutory period is not merely mandatory but jurisdictional. The company’s contention that it filed on time was not fully substantiated and involved an apparent miscomputation of the appeal period by its counsel. The Court held that such a miscomputation cannot arrest the finality of a judgment; otherwise, the executory character of judgments would be left to the whim of the losing party, undermining the need for finality to be fixed and ascertainable.
Since the appeal was not timely perfected, the arbitrator’s award had attained finality and became the law of the case, which must be complied with regardless of any perceived error. Consequently, the Supreme Court found no need to delve into the substantive merits of the dismissal for insubordination. The final award of a labor arbitrator, acting within his authority, has the effect of res judicata, as the parties have submitted to him as a tribunal of last resort. The decision set aside the NLRC’s ruling and reinstated the arbitrator’s award in its entirety.