G.R. No. 87530. June 13, 1990.
GERONIMO SADOL, petitioner, vs. PILIPINAS KAO, INC., REQUITO VEGA, BELEN GOMEZ, ARTURO GOMEZ & NLRC SECOND DIVISION, respondents.

FACTS

Petitioner Geronimo Sadol was recruited by private respondents, owners of Vega & Co., a recruitment agency, for assignment at respondent Pilipinas Kao, Inc. (PKI). He alleged he was summarily dismissed on April 16, 1984. On July 24, 1986, he filed a complaint for reinstatement and backwages. The labor arbiter, after private respondents failed to submit their position papers, rendered a decision on June 26, 1987, ordering private respondents to jointly pay Sadol separation pay. Sadol timely appealed this decision to the NLRC. Private respondents also appealed, but their appeal was filed out of time.
On August 26, 1988, the NLRC promulgated a decision modifying the labor arbiter’s ruling, ordering PKI to reinstate Sadol with backwages, while dismissing private respondents’ appeal for being filed late. PKI received a copy of this NLRC decision on September 13, 1988, and filed a motion for reconsideration on September 22, 1988. The NLRC, in a resolution dated September 30, 1988, granted the motion, set aside its August 26 decision, and dismissed Sadol’s complaint for lack of merit. Sadol’s motion for reconsideration of this reversal was denied.

ISSUE

The core legal issue is whether a party (PKI) that failed to file a timely appeal from the labor arbiter’s decision can subsequently file a motion for reconsideration of the NLRC’s decision rendered on the timely appeal of the adverse party (Sadol).

RULING

The Supreme Court ruled in the affirmative, upholding the NLRC’s authority to entertain PKI’s motion for reconsideration. The Court acknowledged that PKI’s failure to appeal the labor arbiter’s decision within the reglementary period rendered that decision final and executory as to PKI. However, since Sadol had perfected his own timely appeal, the NLRC acquired jurisdiction over the entire case and was empowered to review it. Consequently, when the NLRC rendered its August 26, 1988 decision, a copy of which was duly furnished to PKI, PKI retained the right to file a motion for reconsideration of that specific NLRC decision.
The Court emphasized that rules of technicality must yield to the broader interests of justice. Allowing PKI’s motion for reconsideration enabled the NLRC to equitably evaluate the conflicting factual claims of the parties. The Court found that the NLRC’s subsequent resolution, which dismissed Sadol’s complaint, was supported by substantial evidence. This evidence included a clearance certificate indicating the contractor’s status, payrolls, affidavits from co-workers stating Sadol had abandoned his job to seek work abroad, and a memorandum sent to Sadol regarding his absence. The Court held these factual findings of the NLRC to be conclusive. Therefore, the petition was dismissed for lack of merit.