FACTS
Francisco A. Labao, proprietor of San Miguel Protective Security Agency (SMPSA), employed respondents as security guards assigned to the National Power Corporation. The employees filed complaints for illegal dismissal, money claims, and other labor benefits before the Labor Arbiter (LA). The LA ruled in favor of Labao and dismissed the complaints, holding that the respondents had failed to prove illegal dismissal. On appeal, the National Labor Relations Commission (NLRC) affirmed the LA's decision and later denied the employees' motion for reconsideration, making the decision final unless timely challenged.
The respondents sought relief through a Petition for Certiorari under Rule 65 of the Rules of Court before the Court of Appeals (CA). However, the petition was filed 28 days beyond the 60-day reglementary period prescribed under Section 4, Rule 65. They argued that the delay was caused by the negligence of their former counsel, who failed to inform them of the NLRC's resolution after his secretary allegedly misplaced the notice. The CA nevertheless relaxed the procedural rules in the interest of substantial justice, entertained the petition, reversed the NLRC, and declared that the respondents had been illegally dismissed. It ordered their reinstatement or, in lieu thereof, payment of separation pay, full backwages, allowances, and other statutory benefits.
Labao elevated the case to the Supreme Court, arguing that the CA had no jurisdiction to entertain an untimely petition because the NLRC decision had already become final and executory. He maintained that notice to counsel is notice to the client and that the negligence of counsel could not excuse the late filing of the petition. The controversy centered on whether the CA validly relaxed the procedural rules and assumed jurisdiction over the petition despite its late filing.
ISSUE
Whether the Court of Appeals erred in giving due course to the respondents' Petition for Certiorari despite its late filing in violation of Section 4, Rule 65 of the Rules of Court.
Whether the negligence of respondents' former counsel constituted an exception to the general rule that notice to counsel is notice to the client, thereby justifying the relaxation of procedural rules.
Whether the NLRC decision had already attained finality, making it immutable and beyond judicial review.
HELD
The Supreme Court granted the petition and reversed the Court of Appeals. It held that the respondents' Rule 65 petition was filed beyond the mandatory 60-day period under Section 4, Rule 65 of the Rules of Court. The Court emphasized that although procedural rules may be relaxed in exceptional cases, the party invoking liberality must present special, compelling, and meritorious reasons. Mere negligence of counsel in failing to notify the client of an adverse judgment does not automatically justify the suspension of procedural rules. Under the long-established rule, notice to counsel of record is notice to the client, and the acts or omissions of counsel generally bind the client.
The Court further ruled that the negligence alleged by the respondents did not amount to the kind of gross, reckless, and inexcusable negligence that would deprive them of due process. Accepting such an excuse would allow litigants to evade the finality of judgments simply by attributing delays to their lawyers. Consequently, the respondents' failure to file the petition within the reglementary period rendered the NLRC Resolution final and executory, and under the doctrine of immutability of judgments, a final judgment can no longer be modified, altered, or reviewed, even if the modification is intended to correct an alleged error of fact or law. The Court stressed that this doctrine promotes stability in the administration of justice and protects the prevailing party's vested rights.
Accordingly, the Supreme Court held that the Court of Appeals acted without jurisdiction in entertaining the belated petition for certiorari. Since the NLRC decision had already attained finality, the CA should have dismissed the petition outright rather than review its merits. The Court therefore reinstated the Labor Arbiter's decision, reaffirming that strict observance of reglementary periods is indispensable to the orderly administration of justice and that the relaxation of procedural rules remains the exception rather than the rule
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