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ADTEL v. MARIJOY A. VALDEZ

FACTS:

Adtel, Inc. hired Marijoy A. Valdez as an accountant. Respondent was promoted as the company's purchasing and logistics supervisor. Adtel entered into a dealership agreement with respondent's husband to distribute their products. Respondent's husband filed a civil case against Adtel and a criminal complaint for libel. Adtel issued a memorandum directing respondent to show cause why she should not be terminated for conflict of interest and serious breach of trust. Respondent denied the charges. Adtel terminated respondent and she filed a complaint for illegal dismissal. The Labor Arbiter dismissed the complaint, ruling that there was a conflict of interest and just cause for her dismissal. The NLRC, however, reversed the Labor Arbiter's decision and granted respondent's appeal, finding that Adtel failed to prove just cause for terminating respondent's employment. Adtel filed a motion for reconsideration which was denied. Adtel then filed a petition for certiorari with the Court of Appeals (CA) but it was dismissed for being filed beyond the reglementary period. Adtel's motion for reconsideration was also denied. Adtel now presents issues for the Court's consideration.

ISSUES:

  1. A. The Court of Appeals committed a reversible error in denying the petitioners' motion for reconsideration and in dismissing the petition for certiorari on the sole basis of technicality.

  2. B. Technicalities should give way to a judgment on the merits considering that the Labor Arbiter justly and correctly ruled that the complaint for illegal dismissal against petitioner was baseless and unmeritorious only to be later reversed by the NLRC upon respondent's appeal.

RULING:

  1. The Supreme Court denied the petition. The Court held that the Court of Appeals did not commit reversible error in denying the motion for reconsideration and dismissing the petition for certiorari based on the technicality of the late filing. The Court cited A.M. No. 07-7-12-SC which amended Section 4, Rule 65 of the Rules of Court, and held that the reglementary period to file a petition for certiorari cannot be extended. Therefore, despite the merits of the case, the petition was dismissed due to the late filing.

PRINCIPLES:

  • The reglementary period to file a petition for certiorari cannot be extended. (A.M. No. 07-7-12-SC)

  • Technicalities should not be given way to a judgment on the merits when there is a failure to comply with reglementary periods.