GR L 51607; (December, 1982) (Digest)
G.R. No. L-51607 December 15, 1982
CESAR ACDA, petitioner, vs. The MINISTER OF LABOR and PAN ORIENTAL MATCH CO., INC., respondents.
FACTS
Petitioner Cesar Acda was appointed as a Sales Supervisor Trainee on September 26, 1976, with his employment contract stating a temporary term of one month, after which he could be given a probationary appointment if his performance was satisfactory. He was dismissed effective January 31, 1977, within his probationary period, on the grounds of “loss of confidence and want in capabilities.” Acda filed a complaint for illegal dismissal, arguing the grounds were baseless, that he was denied due process, and that his dismissal was a plot to circumvent security of tenure. The Labor Arbiter ruled in Acda’s favor, ordering his reinstatement with full back wages, finding the charges flimsy and noting he had received a congratulatory letter from the company president for excellent performance. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter’s decision.
The respondent company appealed to the Minister of Labor. The Deputy Minister, by authority of the Minister, reversed the NLRC, upholding the dismissal on the basis that the company could terminate a probationary employee if he failed to meet its standards. Acda then filed this petition for certiorari, challenging the Minister’s jurisdiction to entertain the appeal and seeking reinstatement of the NLRC resolution.
ISSUE
Whether the Minister of Labor had jurisdiction to entertain the company’s appeal from the NLRC resolution.
RULING
No. The Supreme Court granted the petition, setting aside the Order of the Minister of Labor. The Court held that the perfection of an appeal within the reglementary period is both mandatory and jurisdictional. The NLRC resolution explicitly noted that the company’s appeal to the Commission was not perfected, as it was filed in only seven copies instead of the required ten and no appeal fee was paid. Consequently, the Labor Arbiter’s decision had become final and executory. The Minister of Labor therefore lacked jurisdiction to alter that final judgment by entertaining a further appeal.
While technical rules of procedure are generally not strictly applied in labor cases, the Court emphasized that the rule on the perfection of appeals is fundamental to finality of judgments. The Minister’s assumption of jurisdiction was a reversible error. On the substantive issue, the Court found that the ground of “loss of confidence” invoked for dismissal was without basis and could not be used arbitrarily, especially given evidence of Acda’s satisfactory performance. The Court reinstated the NLRC resolution affirming the Labor Arbiter’s decision, but limited the award of back wages to three years without qualification or deduction.