Annulment of NLRC Judgments: Why the Court of Appeals Lacks Jurisdiction

The Supreme Court's ruling in Elcee Farms, Inc. v. Semillano (G.R. No. 150286, October 17, 2003) clarifies a critical procedural point in Philippine labor law: the Court of Appeals has no jurisdiction to annul a final and executory judgment of the National Labor Relations Commission (NLRC). The decision also serves as a cautionary tale about the consequences of forum shopping and the importance of diligently pursuing available remedies.

The Case Background

The dispute began when 144 employees filed a complaint for illegal dismissal against Elcee Farms, Inc., Corazon Saguemuller, and other respondents. Of these, only 28 employees submitted affidavits and evidence of employment. The Labor Arbiter initially ordered Hilla Corporation to pay separation pay to these 28 employees but dismissed claims against the other respondents.

On appeal, the NLRC modified the decision, holding all defendants liable and adding moral damages. Later, the NLRC issued another resolution that absolved Hilla Corporation, held only Elcee Farms and Saguemuller liable, and increased the number of awardees from 28 to 131 based on SSS contribution records.

The Procedural Missteps

The petitioners filed two separate petitions for certiorari with the Supreme Court. The first was dismissed for failure to file the petition within the extension period granted. The second was dismissed for non-compliance with a resolution requiring payment of costs and submission of memoranda—a resolution that was sent to the wrong address.

Instead of seeking reinstatement of their second petition, the petitioners filed a petition for annulment of judgment with the Court of Appeals. The appellate court dismissed the petition for lack of jurisdiction, ruling that Rule 47 of the Rules of Court applies only to decisions of regional trial courts, not quasi-judicial bodies like the NLRC.

The Supreme Court's Ruling

The Supreme Court affirmed the Court of Appeals' dismissal. Under Section 9 of Batas Pambansa Blg. 129, the Court of Appeals has exclusive jurisdiction over actions for annulment of judgments of Regional Trial Courts—not the NLRC. The exact statutory text of this provision is not reproduced in the decision, but the Court relied on this grant of jurisdiction to conclude that the appellate court lacked authority over NLRC judgments.

The Court also noted that annulment of judgment is available only when ordinary remedies like new trial, appeal, or petition for relief are no longer available through no fault of the petitioner. Here, the petitioners had the remedy of certiorari but failed to pursue it diligently.

Forum Shopping and Its Consequences

The Court found that the petitioners' actions constituted forum shopping—repetitively availing of several judicial remedies in different courts, all substantially founded on the same transactions and raising the same issues. The Court described forum shopping as "an act of malpractice that is prohibited and condemned as trifling with the courts and abusing their processes."

The Exception to the General Rule

While the general rule is that a client is bound by the negligence or mistake of counsel, the Court acknowledged exceptions. Citing Government Service Insurance System v. Bengson Commercial Buildings, Inc., the Court noted that the rule may be relaxed to prevent a miscarriage of justice. The Court expressed concern about the validity of service of the resolution in the second certiorari petition, which was sent to the wrong address, and about the NLRC's increase of awardees from 28 to 131 based solely on SSS records.

However, the Court held that these concerns could not be raised in a petition for annulment of judgment before the Court of Appeals. They were proper questions for the certiorari petition before the First Division, should it decide to reinstate the petition.

Practical Takeaways

• The Court of Appeals cannot annul NLRC judgments; Rule 47 applies only to decisions of regional trial courts.
• Annulment of judgment is a remedy of last resort, available only when other remedies are no longer available through no fault of the petitioner.
• Filing multiple petitions in different courts based on the same facts and issues constitutes forum shopping, which the courts strongly condemn.
• While the general rule binds clients to their counsel's mistakes, courts may relax this rule in exceptional circumstances to prevent injustice.
• Diligence in pursuing remedies is crucial; failure to comply with court requirements can result in dismissal, even if the dismissal is not on the merits.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.