Systems Factors Corporation vs. National Labor Relations Commission

Procedural laws, such as amendments to the Rules of Civil Procedure, apply retroactively to actions pending and undetermined at the time of their passage, and thus the 60-day period to file a petition for certiorari is reckoned from the notice of the denial of a motion for reconsideration under the amended Rule 65.

Systems Factors Corporation is engaged in the business of installing electrical systems in buildings and infrastructure projects, employing electricians, engineers, and other personnel. Private respondents Ronaldo Lazaga and Luis Singson were employed by the corporation as electricians in one of its projects. The dispute centers on the procedural period to file a petition for certiorari under Rule 65 of the 1997 Rules of Civil Procedure, specifically the effect of an amendment (A.M. No. 00-2-03-SC) that took effect on September 1, 2000, while the case was pending resolution before the Supreme Court.

Systems Factors Corporation, engaged in the electrical installation business, employed Ronaldo Lazaga and Luis Singson as electricians in one of its projects. Lazaga and Singson filed a complaint against the corporation and its officer, Modesto Dean, for illegal dismissal and non-payment of backwages, service incentive fees, premium pay, separation pay, and other allowances. The Labor Arbiter ruled in favor of the employees, ordering reinstatement and payment of backwages. The National Labor Relations Commission (NLRC) affirmed this decision on appeal.

Petitioners received the NLRC judgment on August 10, 1999, and filed a motion for reconsideration on August 20, 1999. On November 25, 1999, they received the NLRC resolution dated November 11, 1999, denying their motion. On January 24, 2000, petitioners filed a petition for certiorari under Rule 65 with the Court of Appeals. The Court of Appeals dismissed the petition on February 15, 2000, citing procedural deficiencies: the petition was filed out of time, and the documents and material portions referred to in the petition were not certified, except for the assailed NLRC resolutions. Petitioners moved for reconsideration, and the Court of Appeals partially relented, relying on a Supreme Court ruling to accept that only the questioned resolution needed certification. However, the motion for reconsideration was denied in its Resolution dated June 22, 2000, because the Court of Appeals maintained that the petition was filed out of time. Under the rule then prevailing, the 60-day period to file a certiorari petition was reckoned from the receipt of the NLRC resolution dismissing the appeal, interrupted only by the motion for reconsideration. The CA calculated that petitioners had 50 days remaining from November 25, 1999, giving them until January 14, 2000 to file, making the January 24, 2000 filing late.

Petitioners elevated the matter to the Supreme Court, invoking A.M. No. 00-2-03-SC, which took effect on September 1, 2000. This amendment to Section 4, Rule 65 of the 1997 Rules of Civil Procedure provides that if a motion for reconsideration is timely filed, the 60-day period is counted from notice of the denial of the motion. Under this amendment, the January 24, 2000 filing would have been within the reglementary period. Respondents countered that applying the amendment retroactively would multiply similar requests for liberality and that the Labor Code mandates resolving conflicts in favor of labor.

• Applicability of the Amended Rule: Petitioners argued that A.M. No. 00-2-03-SC, which took effect on September 1, 2000, should apply because it reckons the 60-day period from receipt of the resolution denying the motion for reconsideration, making their filing timely.
• Logical Construction of the Rule: Petitioners maintained that since a motion for reconsideration is a mandatory pleading before filing a petition for certiorari, it is logical to assume the 60-day period should be reckoned from the notice of the resolution denying the motion.
• Liberal Construction: Petitioners argued that remedial laws should be construed liberally to give litigants ample opportunity to prove their claims and avoid denial of substantial justice due to technicalities.

• Avoidance of Multiplicity of Litigation: Respondents contended that the controversy would multiply if similar requests for liberality and exceptions were granted.
• Labor Code Preference: Respondents argued that the Labor Code mandates that conflicts in the interpretation of laws and rules be resolved in favor of the working man.
• Denial of Liberality: Respondents asserted that the plea for liberality should be denied because the delay was due to the neglect of counsel, which does not warrant an exception to the rule.

• Retroactivity of Procedural Laws: Whether the amendment to Section 4, Rule 65 of the 1997 Rules of Civil Procedure under A.M. No. 00-2-03-SC, which took effect on September 1, 2000, applies retroactively to a petition for certiorari filed before the amendment's effectivity but pending resolution at the time of its effectivity.

• Retroactivity of Procedural Laws: Yes. The amendment under A.M. No. 00-2-03-SC applies, as procedural laws are retroactive to actions pending and undetermined at the time of their passage.

• Retroactivity of Procedural Laws: Remedial statutes or statutes relating to remedies or modes of procedure do not create new or take away vested rights, but only operate in furtherance of the remedy or confirmation of rights already existing. Therefore, they do not come within the legal conception of a retroactive law or the general rule against retroactive operation. Statutes regulating the procedure of the courts are construed as applicable to actions pending and undetermined at the time of their passage. The retroactive application of procedural laws is not violative of any right of a person who may feel adversely affected, because no vested right attaches to procedural laws. This conclusion aligns with Section 6, Rule 1 of the 1997 Rules of Civil Procedure, which mandates liberal construction to secure a just, speedy, and inexpensive disposition of every action. Thus, the 60-day period should be reckoned from the receipt of the resolution denying the motion for reconsideration, making the petition timely.

• Retroactivity of Procedural Laws — Remedial statutes or statutes relating to remedies or modes of procedure, which do not create new or take away vested rights but only operate in furtherance of the remedy or confirmation of rights already existing, are retroactive in that they apply to actions pending and undetermined at the time of their passage. No vested right attaches to procedural laws, so their retroactive application does not violate any right. The Court applied this doctrine to hold that the amendment to Section 4, Rule 65 (A.M. No. 00-2-03-SC) applied to the pending case, allowing the 60-day period for filing a certiorari petition to be reckoned from the denial of the motion for reconsideration.

• "Remedial statutes or statutes relating to remedies or modes of procedure, which do not create new or take away vested rights, but only operate in furtherance of the remedy or confirmation of rights already existing, do not come within the legal conception of a retroactive law, or the general rule against retroactive operation of statutes." — This passage defines the nature of procedural laws and provides the ratio decidendi for why they can be applied retroactively to pending cases.
• "Statutes regulating to the procedure of the courts will be construed as applicable to actions pending and undetermined at the time of their passage. Procedural laws are retroactive in that sense and to that extent." — This articulates the canonical formulation of the rule on the retroactive application of procedural laws.

• Cadayona vs. Court of Appeals, et. al., G.R. No. 128772 — Cited by the Court of Appeals in its resolution denying the motion for reconsideration, giving weight to the submission that only the questioned resolution need be certified.
• Castro vs. Sagales, 94 Phil. 208 — Cited to support the proposition that remedial statutes do not come within the legal conception of a retroactive law.
• Gregorio vs. Court of Appeals, 26 SCRA 229; Tinio vs. Mina, 26 SCRA 512 — Cited to support the rule that statutes regulating court procedure apply to pending and undetermined actions.
• Billones vs. CIR, 14 SCRA 674 — Cited to support the principle that no vested right may attach to procedural laws.

• Section 4, Rule 65, 1997 Rules of Civil Procedure (as amended by A.M. No. 00-2-03-SC) — Provides that the petition for certiorari shall be filed not later than sixty (60) days from notice of the judgment, and if a motion for reconsideration is timely filed, the 60-day period shall be counted from notice of the denial of said motion. The Court applied this amended provision retroactively to hold that the petition was filed on time.
• Section 6, Rule 1, 1997 Rules of Civil Procedure — Mandates that the Rules shall be liberally construed to promote their objective of securing a just, speedy, and inexpensive disposition of every action and proceeding. The Court relied on this to support its conclusion favoring the petitioners.

Melo, (Chairman), Vitug, and Panganiban, JJ., concur.