RICHARD DANTE L. CARANDANG, PETITIONER, VS. NATIONAL LABOR RELATIONS COMMISSION, ISI TELETRADE, INC. AND PETER STEINBACH, RESPONDENTS.

Carandang versus National Labor Relations Commission

The Case

This is a labor case that reached the Supreme Court on a question of procedure rather than substance. Richard Dante Carandang, a dismissed employee, sought relief from the Supreme Court after the National Labor Relations Commission ruled his dismissal illegal but awarded him compensation he considered too low. He filed a motion asking for more time to file a petition for certiorari, and the Court had to decide whether that extension should be granted. The case matters because it is a compact lesson on the strictness of procedural deadlines and on when the Court will relax them.

Procedural History

The National Labor Relations Commission ruled that Carandang's dismissal was illegal, but Carandang disputed the amount of compensation the Commission awarded. He did not question the finding of illegality; he questioned only the money. He then filed with the Supreme Court a Manifestation with Motion for Time to File Petition for Review, asking for an additional fifteen days to file a petition for certiorari under Rule 65 of the 1997 Rules of Civil Procedure, on the ground that he was suffering from a medical ailment. While that motion was pending, the Petition for Review itself, dated May 7, 2014, was submitted to the Court and received on May 19, 2014. The Supreme Court resolved the motion and the petition together.

Facts

Carandang was an employee whose dismissal the National Labor Relations Commission declared illegal. He accepted that ruling but was dissatisfied with the compensation the Commission awarded him, and he wanted the Supreme Court to review the amount.

To bring that question up, he needed to file a petition for certiorari under Rule 65 within the reglementary period. Instead of filing on time, he filed a Manifestation with Motion for Time to File Petition for Review, asking for an additional fifteen days. His stated reason was that he was suffering from a medical ailment.

The petition itself, dated May 7, 2014, was submitted to the Court and received on May 19, 2014, while the motion for extension remained pending. The Court therefore had before it both the request for more time and the late petition.

Issues

• Whether or not the Supreme Court should grant the motion for an extension of time to file a petition for certiorari under Rule 65 on the ground of the petitioner's medical ailment.
• Whether or not the petition for review, filed while the motion for extension was pending, should be given due course.

Applicable Provisions

Rule 65 of the 1997 Rules of Civil Procedure governs the petition for certiorari that the petitioner sought to file, and its reglementary period is what the motion for extension sought to stretch. The Court did not quote the Rule itself, but it treated the period as binding and the extension as a matter of sound discretion, not of right.

The Court relied on its own ruling in Castells versus Saudi Arabian Airlines, which set out when procedural rules may be relaxed:

It is well-settled that procedural rules should be treated with utmost respect and due regard, since they are designed to facilitate the adjudication of cases to remedy the worsening problem of delay in the resolution of rival claims and in the administration of justice. From time to time, however, the Court has recognized exceptions to the strict application of such rules, but only for the most compelling reasons where stubborn obedience to the Rules would defeat rather than serve the ends of justice.

That passage supplies the standard the Court applied: relaxation is allowed only for the most compelling reasons.

Ruling

On the first issue, the Court denied the motion for time to file. It found no compelling reason to grant the request for extension. Although the petitioner was suffering from a medical condition, that condition did not justify the failure of counsel to prepare the petition for certiorari setting forth his client's legal arguments, arguments with which counsel is presumably more well versed. The client's ailment, the Court said, is not a hindrance to the preparation of the petition as counsel would have the Court believe.

On the second issue, because the extension was denied, the Petition for Review was considered a mere scrap of paper. The Court thus declined to give it due course.

Doctrine

First, procedural rules must be treated with utmost respect and due regard, and they may be relaxed only for the most compelling reasons where stubborn obedience to the rules would defeat rather than serve the ends of justice. Second, a motion for extension of time to file a petition for certiorari under Rule 65 is addressed to the sound discretion of the Court and is not granted as a matter of course. Third, a client's illness does not excuse counsel's failure to prepare and file the petition on time, because the preparation of legal arguments is the work of counsel, not of the client. Fourth, a petition filed without a granted extension is a mere scrap of paper and will not be given due course.

Disposition

The motion for time to file petition for review was denied and the case was dismissed, so the respondents prevailed and the petition was not given due course.

Remember This

The single line worth memorizing is that a client's medical ailment does not excuse counsel from preparing the petition on time, and a petition filed without a granted extension is a mere scrap of paper. Examiners use this case on the strictness of the reglementary period under Rule 65 and on the narrow, compelling-reason standard for relaxing procedural rules.