U-SING BUTTON v. NATIONAL LABOR RELATIONS COMĀ­MISSION

FACTS:

The case involves a claim for separation benefits filed by Cecilia Naya against U-Sing Button and Buckle Industry and its proprietor and general manager, Sy Ban, after the death of her husband, Fortunato Naya. Fortunato Naya worked as a maintenance worker for the company for 26 years before he stopped working due to illness and subsequently passed away. The parties were unable to settle the claim amicably, leading to the submission of their respective position papers. U-Sing Button and Buckle Industry presented evidence of Fortunato Naya's alleged indebtedness to them, while Cecilia Naya denied any debts and alleged that the signatures on the acknowledgement of obligations were forged and the documents fabricated. The Labor Arbiter rendered a decision dismissing the claim for underpayment but ordered the respondents to pay separation benefits to Cecilia Naya. The respondents appealed the decision to the National Labor Relations Commission (NLRC), but their appeal was dismissed due to the failure to post a surety bond equivalent to the monetary award. The respondents' motion for reconsideration was also denied by the NLRC. In their petition for certiorari, the respondents raised issues regarding the jurisdiction of the NLRC, the dismissal of their appeal for failure to post a bond, and the alleged error of the NLRC in not rendering judgment in their favor. However, the Supreme Court found that the NLRC had jurisdiction over the case, upheld the requirement of a surety bond for the perfection of an appeal, and affirmed the decision of the NLRC ordering the payment of separation benefits to Cecilia Naya.

ISSUES:

  1. Whether the NLRC had jurisdiction over the case due to the non-confirmation of the appointments of the commissioners.

  2. Whether the failure of the petitioners to file a surety bond is a valid ground for the dismissal of the appeal.

  3. Whether the NLRC erred in not rendering judgment in favor of the petitioners and against the private respondent.

RULING:

  1. The non-confirmation of the appointments of the commissioners by the Commission on Appointments did not render their appointments null and void. The NLRC had jurisdiction over the case as the commissioners' acts are valid. Furthermore, the petitioners are estopped from repudiating the jurisdiction of the NLRC which they had already recognized.

  2. The surety bond is required for the perfection of an appeal to the NLRC. The petitioners failed to post a surety bond from a reputable bonding company in the amount equivalent to the monetary award in the judgment appealed from. This failure is a valid ground for the dismissal of the appeal.

  3. The NLRC did not err in rendering judgment in favor of the private respondent and ordering the petitioners to pay separation benefits. The factual findings of the NLRC and the Labor Arbiter will not be reviewed in a certiorari petition unless they are wildly distorted or contradicted by the findings of another administrative body, which does not exist in this case.

PRINCIPLES:

  • The Chairman and members of the NLRC are not among the officers mentioned in the Constitution whose appointments require confirmation by the Commission on Appointments.

  • An appeal is a purely statutory right and must strictly comply with the requirements spelled out in the Rules.

  • The equivalence between the amount of the appeal bond and the monetary award, excluding moral and exemplary damages, validates an interpretation that limits the amount of the bond to the sums awarded other than in the concept of moral and exemplary damages.

  • All doubts in the interpretation of labor and social laws should be resolved in favor of the worker.