STAR ANGEL HANDICRAFT, vs. NATIONAL LABOR RELATIONS COMMISSION (THIRD DIVISION) and Spouses HELEN AND JOLITO FRIBALDOS.
- G.R. Number: G.R. No. 108914
- Promulgated: 1994-09-20
- Ponente: Quiason, J.
Doctrine
Posting a cash or supersedeas bond equivalent to the award is mandated by Article 223 of the Labor Code and is required to perfect an appeal; however, the NLRC may allow reduction of the bond for compelling, proven reasons, and bond posting must precede any reduction. (¶17, ¶38)
A motion to reduce the appeal bond may be filed within the reglementary appeal period in lieu of filing the contested bond; the appeal is not perfected and the labor arbiter retains jurisdiction until the NLRC acts on the motion and the bond, as fixed by the NLRC, is posted. (¶38)
The Court has relaxed strict bond requirements in meritorious cases and cautioned the NLRC to interpret Article 223 liberally to resolve controversies on their merits. (¶40, ¶41)
Facts
Petitioner sought relief by certiorari under Rule 65 to set aside two NLRC resolutions: the 23 October 1992 Resolution in NLRC Case No. RAB-IV-2-4223-92 RI and the 21 January 1993 resolution denying reconsideration. (¶4)
NLRC dismissed petitioner's appeal for failure to post an appeal bond based on Article 223 of the Labor Code. (¶17, ¶22)
Petitioner filed a motion to reduce the appeal bond amount, which the NLRC refused to act on before dismissing the appeal. (¶22, ¶38)
Issues
Whether the NLRC acted with grave abuse of discretion when it refused to act on petitioner's motion to reduce the appeal bond and dismissed the appeal for failure to post the bond.
Ruling
The Court granted the certiorari petition, set aside the NLRC Resolutions of 23 October 1992 and 21 January 1993, and directed the NLRC Third Division to act on the motion to reduce the appeal bond and to accept petitioner's appeal after filing the appropriate bond. (¶5, ¶42)