July 2010 - Philippine Supreme Court Resolutions
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[G.R. No. 182893 : July 02, 2010] MANILA ELECTRIC COMPANY (MERALCO) V. EDGARDO C. ILAGAN, ET AL. :
[G.R. No. 182893 : July 02, 2010]
MANILA ELECTRIC COMPANY (MERALCO) V. EDGARDO C. ILAGAN, ET AL.
Sirs/Mesdames:
Please take notice that the Court, Second Division, issued a Resolution dated 02 July 2010, which reads as follows:
G.R. No. 182893* (Manila Electric Company (MERALCO) v. Edgardo C. Ilagan, et al.).
This case is about when the National Labor Relations Commission (NLRC) may relax its rules to give due course to a motion for reconsideration that a party filed after first asking for an extension of time within which to file such motion.
On July 21, 2000 the respondents Edgardo C. Ilagan, et al., officers and members of MERALCO Employees and Workers Union (the Union), staged a strike against petitioner Manila Electric company (MERLACO). Because of the vital nature of MERALCO's business, the Labor Secretary issued a return-to-work order and assumed jurisdiction over the labor dispute.
On August 2, 2000 the parties mutually agreed: 1) to end the strike; and 2) for petitioner MERALCO to accept the striking employees, except for the 13 union officers who were given termination notice and another 13 who faced administrative or criminal cases. After concluding its administrative investigation, Meralco dismissed 66 of the striking personnel, including the respondents, for having committed illegal and prohibited acts during the strike and defied the return-to-work order. The respondent employees protested their dismissal as illegal.
On August 6, 2003 the NLRC ruled as valid MERALCO's dismissal of respondent employees but granted them separation pay of one month for every year of service[1] considering the substantial length of service that they had rendered to MERALCO. Both parties sought reconsideration of the NLRC decision with the respondent employees questioning the validity of their dismissal and MERALCO, the award of separation pay.
On April 19, 2004 the NLRC issued the assailed resolution dismissing respondent employees' motion for reconsideration for having been filed out of time (they first filed a motion for extension of time within which to file a motion for reconsideration) while granting that of MERALCO.[2] The NLRC easily conceded that an award of separation pay was allowable only in instances of valid dismissal for cause other than serious misconduct.
Consequently, in lieu of separation pay, the NLRC ordered MERALCO to give respondent employees financial assistance of P10,000.00 each, given the considerable numbers of years for which they served MERALCO.
Respondent employees challenged the dismissal of their motion for reconsideration by filing a special civil action for certiorari with the Court of Appeals (CA).[3] On January 23, 2008 the CA reversed the NLRC's April 19, 2004 resolution and ordered it to resolve respondent employees' motion for reconsideration.[4] MERALCO moved for the reconsideration of the CA decision but the court denied the motion,[5] prompting MERALCO to file this petition for review.
The only question presented in this case is whether or not the CA erred in ordering the NLRC to resolve respondent employees' motion for reconsideration after it filed a motion for extension of time within which to file the same.
The Court finds no convincing reason to reverse the CA decision. The established tenet is that the NLRC is not bound by technical rules of procedure[6] in resolving labor disputes. This is all the more so when its rules do not specifically prohibit the filing a motion for extension of time to file a motion for reconsideration. Further, as the Court ruled in Lamsam Trading, Inc. v. Leogardo, Jr.,[7] the period for filing a motion for reconsideration may be relaxed under compelling circumstances.
Here, the NLRC did not appear pressed for time to immediately resolve the pending incidents in the case. Indeed, it took the NLRC more than six months after the motions for reconsideration had been filed before resolving them. It could have just as well used that time to look into the merits of respondent employees' motion for reconsideration, the NLRC would have better served the ends of justice.
WHEREFORE, the Court DENIES the petition and AFFIRMS the decision dated January 23, 2008 and resolution dated May 15, 2008 of the Court of Appeals in CA-G.R. SP 84799.
SO ORDERED.
G.R. No. 182893* (Manila Electric Company (MERALCO) v. Edgardo C. Ilagan, et al.).
This case is about when the National Labor Relations Commission (NLRC) may relax its rules to give due course to a motion for reconsideration that a party filed after first asking for an extension of time within which to file such motion.
The Facts and the Case
On July 21, 2000 the respondents Edgardo C. Ilagan, et al., officers and members of MERALCO Employees and Workers Union (the Union), staged a strike against petitioner Manila Electric company (MERLACO). Because of the vital nature of MERALCO's business, the Labor Secretary issued a return-to-work order and assumed jurisdiction over the labor dispute.
On August 2, 2000 the parties mutually agreed: 1) to end the strike; and 2) for petitioner MERALCO to accept the striking employees, except for the 13 union officers who were given termination notice and another 13 who faced administrative or criminal cases. After concluding its administrative investigation, Meralco dismissed 66 of the striking personnel, including the respondents, for having committed illegal and prohibited acts during the strike and defied the return-to-work order. The respondent employees protested their dismissal as illegal.
On August 6, 2003 the NLRC ruled as valid MERALCO's dismissal of respondent employees but granted them separation pay of one month for every year of service[1] considering the substantial length of service that they had rendered to MERALCO. Both parties sought reconsideration of the NLRC decision with the respondent employees questioning the validity of their dismissal and MERALCO, the award of separation pay.
On April 19, 2004 the NLRC issued the assailed resolution dismissing respondent employees' motion for reconsideration for having been filed out of time (they first filed a motion for extension of time within which to file a motion for reconsideration) while granting that of MERALCO.[2] The NLRC easily conceded that an award of separation pay was allowable only in instances of valid dismissal for cause other than serious misconduct.
Consequently, in lieu of separation pay, the NLRC ordered MERALCO to give respondent employees financial assistance of P10,000.00 each, given the considerable numbers of years for which they served MERALCO.
Respondent employees challenged the dismissal of their motion for reconsideration by filing a special civil action for certiorari with the Court of Appeals (CA).[3] On January 23, 2008 the CA reversed the NLRC's April 19, 2004 resolution and ordered it to resolve respondent employees' motion for reconsideration.[4] MERALCO moved for the reconsideration of the CA decision but the court denied the motion,[5] prompting MERALCO to file this petition for review.
Question Presented
The only question presented in this case is whether or not the CA erred in ordering the NLRC to resolve respondent employees' motion for reconsideration after it filed a motion for extension of time within which to file the same.
The Court's Ruling
The Court finds no convincing reason to reverse the CA decision. The established tenet is that the NLRC is not bound by technical rules of procedure[6] in resolving labor disputes. This is all the more so when its rules do not specifically prohibit the filing a motion for extension of time to file a motion for reconsideration. Further, as the Court ruled in Lamsam Trading, Inc. v. Leogardo, Jr.,[7] the period for filing a motion for reconsideration may be relaxed under compelling circumstances.
Here, the NLRC did not appear pressed for time to immediately resolve the pending incidents in the case. Indeed, it took the NLRC more than six months after the motions for reconsideration had been filed before resolving them. It could have just as well used that time to look into the merits of respondent employees' motion for reconsideration, the NLRC would have better served the ends of justice.
WHEREFORE, the Court DENIES the petition and AFFIRMS the decision dated January 23, 2008 and resolution dated May 15, 2008 of the Court of Appeals in CA-G.R. SP 84799.
SO ORDERED.
Very truly yours,
(Sgd.) MA. LUISA L. LAUREA
Clerk of Court
Clerk of Court
* J. Mendoza, no part. J. Brion, additional member, per raffle dated June 28, 2010.
[1] Rollo, pp. 40-63.
[2] Id. at 64-67.
[3] Docketed as CA-G.R. SP 84799.
[4] Penned by Associate Justice Mario L. Guari�a III and concurred in by Associate Justices Japar B. Dimaampao and Sixto C. Marella, Jr.
[5] Resolution dated May 15, 2008 denying petitioner MERALCO's motion for reconsideration.
[6] PNOC Dockyard and Engineering Corporation v. National Labor Relations Commission, 353 Phil. 431, 445 (1998).
[7] 228 Phil. 542, 549 (1986).
