GR 74590 91; (March, 1991) (Digest)
G.R. Nos. 74590-91; March 11, 1991
PHILIPPINE AMERICAN TIMBER COMPANY, INC., petitioner, vs. HON. DANTE ARDIVILLA, PABLO W. MONTESCLAROS, MODESTO MONTAÑER, et al., respondents.
FACTS
Petitioner Philippine American Timber Company, Inc. (the COMPANY) had its timber license cancelled by the Ministry of Forest Development in 1979 due to its own failures, including minimal reforestation performance. Consequently, on January 27, 1981, the COMPANY filed an application for clearance to terminate the employment of 120 named employees, citing the phasing out of operations. Eighty-six (86) employees opposed the application, arguing the termination lacked valid cause and alternatively praying for separation pay. The Regional Director granted the clearance on March 20, 1981. The oppositors appealed to the Ministry of Labor, which, in an Order dated April 27, 1983, set aside the clearance. The Ministry ruled the closure was due to the COMPANY’s fault, making the termination illegal, and awarded separation pay to the oppositors. A Partial Alias Writ of Execution was later issued to enforce this award.
ISSUE
The primary issue is whether the Order of the Ministry of Labor dated April 27, 1983, which reversed the grant of clearance and awarded separation pay, was issued without jurisdiction due to the oppositors’ untimely appeal.
RULING
The Supreme Court granted the petition and annulled the Ministry of Labor’s Order and the subsequent writs of execution. The legal logic is grounded in jurisdictional principles. The Court found that notice of the Regional Director’s clearance order was received by the oppositors’ representative on May 16, 1981. Their appeal was filed only on June 12, 1981, which exceeded the mandatory 10-day appeal period prescribed by law. The respondents did not contest these factual assertions. Since the perfection of an appeal within the statutory period is jurisdictional, failure to do so renders the questioned order final and executory. Consequently, the Ministry of Labor had no jurisdiction to entertain the belated appeal or to issue the April 27, 1983 Order. The Court also noted that the writ of execution improperly sought to enforce payment against a significantly larger group than the original 86 oppositors, further demonstrating an excess of authority. Thus, the void Order and all related writs were set aside, and the original clearance granted by the Regional Director was reinstated.