EASTKO APPAREL, INC., PETITIONER, VS. THE NATIONAL LABOR RELATIONS COMMISSION, SIXTH DIVISION, NOEL O. ELI AND DIONITO GAYETANO, JR., RESPONDENTS.

Eastko Apparel versus National Labor Relations Commission

The Case

This is a labor case in which Eastko Apparel, Incorporated, the employer, sought relief against the National Labor Relations Commission, Sixth Division, and against two of its former workers, Noel Eli and Dionito Gayetano, Junior. The employer challenged the labor tribunals' rulings on the dismissal of the two employees. The case matters because it shows how the Supreme Court treats a motion for reconsideration that merely repeats arguments already passed upon, and it reminds the Bar candidate that finality of judgment is the rule and that a motion for reconsideration is not a second appeal.

Procedural History

The dispute began as a labor case docketed before the Labor Arbiter. It reached the National Labor Relations Commission, Sixth Division, which issued a Decision dated February 21, 2014 and a Resolution dated March 31, 2014. The employer then went up to the Supreme Court by petition for review, and the Court rendered a Decision dated October 13, 2014 affirming with modification the rulings of the National Labor Relations Commission. The employer filed a Motion for Reconsideration of that Decision, to which the private respondents filed their Comment. The Court then resolved the motion in the present resolution.

Facts

Eastko Apparel, Incorporated was the employer of Noel Eli and Dionito Gayetano, Junior. The two employees filed a labor complaint, which was docketed as NLRC Case Number RAB-IV-12-01946-12-C and reached the National Labor Relations Commission on appeal as NLRC NCR Case Number LAC-01-000039-14.

The National Labor Relations Commission, Sixth Division, issued a Decision dated February 21, 2014 and a Resolution dated March 31, 2014. The employer elevated the matter to the Supreme Court, which rendered a Decision dated October 13, 2014 affirming with modification the Commission's Decision and Resolution.

Aggrieved, the employer filed a Motion for Reconsideration of the October 13, 2014 Decision. The private respondents filed their Comment on the motion. Upon re-examination of the records, the Court found that the arguments raised in the motion were a mere rehash of the same arguments already amply discussed and passed upon in the decision sought to be reconsidered.

Issues

• Whether or not the arguments raised in the employer's Motion for Reconsideration present cogent reasons to modify, alter, or reverse the Court's Decision dated October 13, 2014.
• Whether or not the Motion for Reconsideration should be granted.

Applicable Provisions

The decision does not quote or construe any statutory provision. It rests on the settled rule that a motion for reconsideration must raise cogent reasons, and that a motion which merely repeats arguments already passed upon is denied for lack of merit. The Court's dispositive language states the governing standard:

WHEREAS, finding no cogent reason to modify, alter or reverse Our findings and conclusions in the assailed decision, petitioner's Motion for Reconsideration is DENIED for lack of merit.

This language bears on the case because it fixes the test the Court applied: absent a cogent reason, the prior decision stands.

Ruling

On the first issue, the Court held that the arguments raised in the Motion for Reconsideration were a mere rehash of the same arguments which had been amply discussed and passed upon in the decision sought to be reconsidered. The Court carefully re-examined the records and found no cogent reason to modify, alter, or reverse its findings and conclusions.

On the second issue, the Court denied the Motion for Reconsideration for lack of merit. The Court explained its ruling in these words:

We carefully re-examined the records and found that the arguments raised in the Motion for Reconsideration are mere rehash of the same arguments which have been amply discussed and passed upon in the decision sought to be reconsidered.

The Court thus declined to disturb its October 13, 2014 Decision affirming with modification the February 21, 2014 Decision and March 31, 2014 Resolution of the National Labor Relations Commission, Sixth Division.

Doctrine

A motion for reconsideration is not a second appeal. It must raise cogent reasons that would justify modifying, altering, or reversing the decision; a motion that merely rehashes arguments already discussed and passed upon is denied for lack of merit. When the Court finds no cogent reason after re-examining the records, the findings and conclusions in the assailed decision stand. The employer's remedy against the labor tribunals' rulings was thus exhausted, and the Commission's Decision and Resolution, as affirmed with modification, became final.

Disposition

The employer lost. The Supreme Court denied Eastko Apparel's Motion for Reconsideration for lack of merit, leaving standing its October 13, 2014 Decision affirming with modification the National Labor Relations Commission's Decision and Resolution.

Remember This

A motion for reconsideration that merely rehashes arguments already passed upon is denied for lack of merit, because a motion for reconsideration is not a second appeal. Examiners use this case to test whether a candidate knows the standard for granting reconsideration and the consequence of failing to raise a cogent reason.