United Placement International v. NLRC

G.R. No. 103370 (June 17, 1996)

Supreme Court upheld dismissal of United Placement's late appeal; timely filing crucial.

Facts:

The case involves a petition for certiorari filed by United Placement International against the National Labor Relations Commission (NLRC) concerning the dismissal of its appeal regarding a decision made by the Philippine Overseas Employment Administration (POEA). The private respondents, Leonardo Arazas, Livy Dacillo, and Cesar Hernandez, applied for overseas employment through Placementhaus and General Services, where they were informed by Virgilio Reyes that they needed to pay a placement fee of P19,300.00 each to facilitate their deployment. The respondents paid the fees but did not receive receipts.

On November 9, 1985, the respondents signed two-year employment contracts, but only Dacillo received a copy. Before their departure to Dammam, Saudi Arabia, in December 1986, they were given sealed envelopes containing employment confirmations, which they were instructed to open only if required by authorities.

After five months of employment, the respondents' contracts were pre-terminated on April 19, 1986, leading to their return to the Philippines. Subsequently, they filed a complaint with the POEA for illegal dismissal, nonpayment of bonuses, and a refund of their placement fees against Placementhaus and United Placement International.

The POEA issued summonses for several hearings, but the petitioner failed to appear on multiple occasions. On March 4, 1987, the petitioner did not show up for the final hearing. The POEA later held Placementhaus responsible for the refund of placement fees and ordered both respondents to be paid their salaries for the unexpired portion of their contracts.

The POEA sent its decision to the petitioner at its old address, which was unclaimed and returned after several notices. The petitioner appealed the decision to the NLRC almost a year later, on September 11, 1989. The NLRC dismissed the appeal, stating it was filed beyond the reglementary period.

Legal Issues:

  1. Whether the appeal filed by United Placement International was timely.
  2. Whether the petitioner was denied due process in the proceedings before the POEA and NLRC.

Arguments:

  • Petitioner’s Argument: The petitioner argued that the service of the POEA decision to its old address should not be considered the starting point for the appeal period, as it had officially changed its address. The petitioner contended that it only received the decision through the initiative of Luz R. Abad on September 1, 1989, making its appeal timely.

  • Respondents’ Argument: The respondents maintained that the petitioner was properly notified of the POEA's decision, and the appeal was filed beyond the ten-day reglementary period. They argued that the petitioner had ample opportunity to be heard but chose to ignore the proceedings.

Court’s Decision and Legal Reasoning:

The Supreme Court affirmed the NLRC's resolution, ruling that the appeal was indeed filed late. The Court held that the petitioner was deemed to have received the POEA decision on August 9, 1988, five days after the first notice from the post office, as per the applicable rules regarding service by registered mail. The Court emphasized that the petitioner had a duty to ensure that it received all official communications at its correct address.

The Court also found that the petitioner was not denied due process, as it had been given multiple opportunities to participate in the hearings but failed to do so. The Court reiterated that the timely perfection of an appeal is mandatory and jurisdictional, and the failure to comply with the reglementary period results in the decision becoming final and executory.

Significant Legal Principles Established:

  1. The service of decisions via registered mail is considered complete upon the expiration of a specified period if the addressee fails to claim the mail.
  2. Parties have a duty to ensure that they receive official communications at their correct addresses.
  3. The timely filing of an appeal is a jurisdictional requirement; failure to comply results in the finality of the decision.