GR L 69769; (October, 1986) (Digest)
G.R. No. L-69769 October 9, 1986
FFW-ARIS PHILIPPINES CHAPTER AND LOURDES BARROZO, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION AND ARIS PHILIPPINES, INC., respondents.
FACTS
Petitioner Lourdes Barrozo, an employee with over five years of service at Aris (Phils.) Inc., was terminated on September 10, 1982, for alleged dishonesty involving a sum of five pesos. She contested her dismissal as illegal, claiming it was without just cause and due process. She filed a complaint for reinstatement and backwages. After conciliation failed, Labor Arbiter Teorico Dogelio dismissed her complaint on December 6, 1982, but ordered the company to provide her with financial assistance of eight hundred pesos. Barrozo appealed this decision to the National Labor Relations Commission (NLRC).
The NLRC dismissed Barrozo’s appeal in a Resolution dated December 15, 1983. The dismissal was based on her alleged failure to furnish a copy of her appeal memorandum to the adverse party, Aris Philippines, Inc. The NLRC treated this omission as a failure to perfect an appeal, rendering the Labor Arbiter’s decision final and executory. Barrozo’s motion for reconsideration was denied, prompting her to file this petition for certiorari, arguing the NLRC gravely abused its discretion.
ISSUE
Whether the National Labor Relations Commission committed grave abuse of discretion in dismissing Lourdes Barrozo’s appeal solely for her failure to furnish a copy of the appeal to the adverse party.
RULING
Yes, the NLRC committed grave abuse of discretion. The Supreme Court ruled that the failure to furnish a copy of the appeal to the adverse party is not a fatal or jurisdictional defect that warrants the dismissal of an appeal. The Court emphasized that appeal is an essential part of the judicial system, and litigants should not be deprived of this right on mere technicalities. In this case, Barrozo, an ordinary factory worker, personally filed her appeal and misunderstood the procedure, believing it was the Ministry of Labor’s obligation to send a copy to the company. This was considered an excusable neglect.
The legal logic is grounded in the principle that rules of procedure should be applied liberally to serve substantial justice, not to override it. Technical rules cannot be used to defeat a party’s right to appeal, especially in labor cases where the constitutional policy of affording protection to labor is paramount. The Court cited applicable jurisprudence, including Carnation Philippines Employees Union-FFW vs. NLRC, which held that such a failure is a mere formal lapse. Consequently, the NLRC’s Resolution was declared null and void, and it was ordered to give due course to Barrozo’s appeal for proper adjudication on the merits.