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GANDARA MILL SUPPLY v. NLRC

FACTS:

Milagros Sy, owner of Gandara Mill Supply, was the respondent in a labor case filed by Silvestre Germano. Germano, without notifying his employer, did not report for work from February 6 to 11, 1995, in order to be near his wife who was about to give birth. Upon private respondent's request, Sy extended financial assistance to the Germano couple. Two weeks later, Germano returned to work and was informed by Sy that someone had been hired to take his place but that he would be re-admitted in June 1996. Germano then filed a case of illegal dismissal with the Department of Labor and Employment. Despite efforts at conciliation, the Labor Arbiter handed down a decision ordering Sy to pay Germano separation pay, backwages, and attorney's fees. Sy appealed the decision to the NLRC, but the appeal was dismissed for failure to post a cash or surety bond. Ultimately, the NLRC affirmed the decision of the Labor Arbiter.

ISSUES:

  1. Did the public respondent act with grave abuse of discretion in dismissing petitioner's appeal and in not giving petitioner a chance to prove that the private respondent was not illegally dismissed but was merely suspended for abandoning his job?

  2. Did the public respondent act with grave abuse of discretion in awarding to the private respondent the amount of P65,685.90, which amount petitioner assails as excessive?

RULING:

  1. The public respondent did not act with grave abuse of discretion in dismissing petitioner's appeal. The Court emphasized that quasi-judicial agencies' findings of fact are conclusive upon the court in the absence of proof of grave error. Petitioner failed to discharge its burden of proof to show that the private respondent was not illegally dismissed.

  2. The public respondent did not act with grave abuse of discretion in awarding the amount of P65,685.90 to the private respondent. The Court held that petitioner's claim that the amount was excessive was unsubstantiated.

PRINCIPLES:

  • Findings of fact by quasi-judicial agencies are conclusive upon the court in the absence of proof of grave error in the appreciation of facts.

  • Reglementary periods are strictly observed to ensure the orderly administration of justice. Exceptions may be made by the agency based on considerations of leniency and equity.

  • The principle of laches applies when there is failure or neglect for an unreasonable length of time to assert a right. It requires the exercise of due diligence in asserting the right within a reasonable time.