**Facts**:
The key events began when Francisco A. Labao, proprietor and general manager of San Miguel Protective Security Agency (SMPSA), issued a memorandum on July 27, 2004, necessitating all security guards, including the respondents who were assigned to the National Power Corporation, Mindanao Regional Center (NPC-MRC) in Iligan City, to update their personal data files by July 30, 2004. The directive aimed at reevaluation for SMPSA’s new service contract with NPC-MRC. The respondents failed to comply, and consequently, were relieved from duty between September and October 2004, with instructions to report for new assignments, which they never received.
In March and April 2005, the respondents filed individual complaints for illegal dismissal and money claims to the NLRC, arguing they had been constructively dismissed due to not being redeployed for over 6 months. The labor arbiter dismissed these complaints, a decision upheld by the NLRC upon appeal. The respondents then filed a petition for certiorari with the CA beyond the prescribed period, alleging delayed notification of the NLRC’s decision.
**Issues**:
1. Whether the CA committed an error in accepting and acting upon the respondents’ petition despite its late filing.
2. Whether the CA erred in reversing the decisions of the labor arbiter and the NLRC, which found no constructive dismissal.
**Court’s Decision**:
The Supreme Court granted Labao’s petition, finding that:
1. The CA erred in entertaining the respondents’ late petition for certiorari. Procedural rules on timely filing are strict to enforce order and efficiency in the judicial process. The respondents’ failure to conform to these regulations rendered the NLRC’s decision final and executory.
2. The negligence of the respondents’ former counsel, which led to the delay, binds the clients. The Court emphasized that exceptions to this principle apply only when the negligence is so gross that it deprives the client of due process.
3. The doctrine of immutability of judgments prevents the alteration of a final and executory decision. Thus, the CA had no jurisdiction to entertain the petition and should have dismissed it.
**Doctrine**:
This case reiterates the doctrine of procedural timeliness and the principle that a client is generally bound by the actions, including mistakes, of his counsel. Additionally, it underscores the immutability of final and executory judgments, reinforcing that such decisions cannot be disturbed by subsequent actions or appeals.
**Class Notes**:
1. **Timeliness of Filing**: A petition for certiorari challenging a court or tribunal’s decision must be filed within 60 days from notice of decision, as per Rule 65 of the 1997 Rules of Civil Procedure. Exceptions are limited and must be justifiable.
2. **Client-Counsel Relationship**: Clients are bound by their counsel’s decisions and actions, including procedural errors, unless the negligence is so gross as to deprive the client of due process.
3. **Immutability of Judgments**: Once a judgment becomes final and executory, it cannot be altered. This principle is crucial for the finality of judgments and the orderly administration of justice.
**Historical Background**:
This case illuminates the procedural intricacies and principles foundational to the Philippine judicial system’s operational efficiency. It emphasizes the balance between strict adherence to procedural rules and the pursuit of substantive justice, highlighting the judiciary’s role in resolving labor disputes. The case also reflects ongoing challenges in labor relations, particularly in security and contractual employment sectors, underpinning the necessity for clear guidelines on employment practices and the significance of due process in labor adjudication.
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