Case Digest: RURAL BANK OF CORON PALAWAN, INC. et al. v. ANNALISA CORTES

RURAL BANK OF CORON PALAWAN, INC. et al. v. ANNALISA CORTES

              Annalisa Cortes (Cortes) was the Corporate Secretary of the Rural Bank of Coron and at the same time, Financial Assistant and the Personnel Officer of the two other corporations. Sandra Garcia Escat, daughter of the founder of the corporations, found out that Annalisa was involved in several anomalies and decided to terminate her. A complaint for illegal dismissal was thereafter filed.

                 The Labor Arbiter ordered Rural Bank et al. to be jointly and severally liable to pay Annalisa a large amount of monetary award. The Rural Bank of Coron Palawan, Inc. et al. alleged that the corporations were under financial distress and the Rural Bank was under receivership and thus, filed their Motion for Reduction of Bond, they prayed that the amount of bond be substantially reduced, preferably one half thereof or even lower.

          The National Labor Relations Commission (NLRC), while noting that the petitioners timely filed the appeal, held that the same was not accompanied by an appeal bond, a mandatory requirement under Article 223 of the Labor Code and Section 6, Rule VI of the NLRC New Rules of Procedure. It ordered the dismissal of the complaint. The Court of Appeals (CA) dismissed the petition. A motion for reconsideration was filed but the same was dismissed.

ISSUE:

Whether or not the decision of the Labor Arbiter is already final and executory

HELD:

In this case, the motion for reduction of appeal bond was filed only on the tenth or final day of the reglementary period. Under such circumstance, the motion for reduction can no longer be deemed to have stayed the appeal, and the Rural Bank of Coron Palawan, Inc. et al faces the risk, as had happened in this case, of summary dismissal of the appeal for non-perfection.

Clearly then, the NLRC has no authority to entertain the appeal, much less to reverse the decision of the Labor Arbiter. Any amendment or alteration made which substantially affects the final and executory judgment is null and void for lack of jurisdiction, including the entire proceeding held for that purpose.
As the court decided, the decision of the Labor Arbiter had become final and executory.