Pepsi-Cola Bottling Company vs. Martinez Facts: On September 19, 1980, respondent Abraham Tumala, Jr.

filed a complaint in the Court of First Instance of Davao, docketed as Civil Case No. 13494, against petitioners Pepsi-Cola Bottling Co., Inc., its president Cosme de Aboitiz and other company officers. Under the first cause of action, the complaint averred inter alia that Tumala was a salesman of the company in Davao City from 1977 up to August 21, 1980; that in the annual Sumakwel contest conducted by the company in 1979, Tumala was declared winner of the Lapu-Lapu Award for his performance as top salesman of the year, an award which entitled him to a prize of a house and lot; and that petitioners, despite demands, have unjustly refused to deliver said prize. Under the second cause of action, it was alleged that on August 21, 1980, petitioners, in a manner oppressive to labor and without prior clearance from the Ministry of Labor, arbitrarily and ilegally terminated his employment. He prayed that petitioners be ordered, jointly and severally, to deliver his prize of house and lot or its cash equivalent, and to pay his back salaries and separation benefits, plus moral and exemplary damages, attorneys fees and litigation expenses. He did not ask for reinstatement. Petitioners moved to dismiss the complaint on grounds of lack of jurisdiction and cause of action and that Tumala is not entitled to the sumakwel prize for misleading the company that he is the top salesman by deception and fraudulent manipulation. CFI denied the motion. Issue: WON the CFI has jurisdiction over the case? Held: NO... On May 1, 1980, Article 217, as amended by P.D. 1367, was amended anew by P.D. 1691. This last decree, which is a verbatim reproduction of the original text of Article 217 of the Labor Code, restored to the Labor Arbiters of the NLRC the exclusive jurisdiction over claims, money or otherwise, arising from employer-employee relations, except those expressly excluded therefrom. In sustaining its jurisdiction over the case at bar, the respondent court relied on Calderon vs. Court of Appeals, where We ruled that an employees action for unpaid salaries, allowances and other reimbursable expenses and damages was beyond the periphery of the jurisdictional competence of the Labor Arbiters. Our ruling in Calderon, however, no longer applies to this case because P.D. 1367, upon which said decision was based, had already been superceded by P.D. 1691. As heretofore stated, P.D. 1691 restored to the Labor Arbiters their exclusive

jurisdiction over said classes of claims. Respondent Tumala maintains that his action for delivery of the house and lot, his prize as top salesman of the company for 1979, is a civil controversy triable exclusively by the court of general jurisdiction. We do not share this view. The claim for said prize unquestionably arose from an employer-employee relation and, therefore, falls within the coverage of par. 5 of P.D. 1691, which speaks of all claims arising from employer-employee relations, unless expressly excluded by this Code. Indeed, Tumala would not have qualified for the contest, much less won the prize, if he was not an employee of the company at the time of the holding of the contest. Besides, the cause advanced by petitioners to justify their refusal to deliver the prizethe alleged fraudulent manipulations committed by Tumala in connection with his duties as salesman of the companyinvolves an inquiry into his actuations as an employee.

San Miguel Corporation vs. NLRC Facts: San Miguel Corporation initiate an invitation for Innovation Program which will undertook grant of cash to the employees who will submit ideas and proposals to improve their San Miguel Beer Grande product. Rustico Vega was an employee of SMC, submits a proposal on pasteurization of the product in order to improve its quality. Petitioner Corporation, however, did not find the aforequoted proposal acceptable and consequently refused Mr. Vegas subsequent demands for a cash award under the Innovation Program. Mr. Vega filed a complaint with Regional Arbitration Branch No. VII (Cebu City) of the then Ministry of Labor and Employment. In an Answer With Counterclaim and Position Paper, petitioner Corporation alleged that private respondent had no cause of action. It denied ever having approved or adopted Mr. Vegas proposal as part of the Corporations brewing procedure in the production of San Miguel Beer Grande. Petitioner further alleged that the Labor Arbiter had no jurisdiction. In an Order4 dated 30 April 1986, the Labor Arbiter, noting that the money claim of complainant Vega in this case is not a necessary incident of his employment and that said claim is not among those mentioned in Article 217 of the Labor Code, dismissed the complaint for lack of jurisdiction. However, in a gesture of compassion and to show the governments concern for the workingman, the Labor Arbiter also directed petitioner to pay Mr. Vega the sum of P2,000.00 as financial assistance. The Labor Arbiters order was subsequently appealed by both parties, private respondent Vega assailing the dismissal of his complaint for lack of jurisdiction and petitioner Corporation questioning the propriety of the award of financial assistance to Mr. Vega. Acting on the appeals, the public respondent National Labor Relations Commission, on 4 September 1987, rendered a Decision ordering the Corporation to pay P60,000.00 to Mr. Vega. In the present Petition for Certiorari filed on 4 December 1987, petitioner Corporation, invoking Article 217 of the Labor Code, seeks to annul the Decision of public respondent upon the ground that the Labor Arbiter and the Commission have no jurisdiction over the subject matter of the case. Issue: WON the Labor Arbiter and the NLRC has jurisdiction over the case? Held: NO!! Where the claim to the principal relief sought is to be resolved not by reference to the Labor Code or other labor relations statute or a collective bargaining agreement but by the general civil

law, the jurisdiction over the dispute belongs to the regular courts of justice and not to the Labor Arbiter and the NLRC. In such situations, resolution of the dispute requires expertise, not in labor management relations nor in wage structures and other terms and conditions of employment, but rather in the application of the general civil law. Clearly. such claims fall outside the area of competence or expertise ordinarily ascribed to Labor Arbiters and the NLRC and the rationale for granting jurisdiction over such claims to these agencies disappears. Applying the foregoing to the instant case, the Court notes that the SMC Innovation Program was essentially an invitation from petitioner Corporation to its employees to submit innovation proposals, and that petitioner Corporation undertook to grant cash awards to employees who accept such invitation and whose innovation suggestions, in the judgment of the Corporations officials, satisfied the standards and requirements of the Innovation Program and which, therefore, could be translated into some substantial benefit to the Corporation. Such undertaking, though unilateral in origin, could nonetheless ripen into an enforceable contractual (facio ut des) obligation on the part of petitioner Corporation under certain circumstances. Thus, whether or not an enforceable contract, albeit implied and innominate, had arisen between petitioner Corporation and private respondent Vega in the circumstances of this case, and if so, whether or not it had been breached, are preeminently legal questions, questions not to be resolved by referring to labor legislation and having nothing to do with wages or other terms and conditions of employment, but rather by having recourse to our law on contracts.

Dayag vs. Canizares, Jr. Facts: On March 11, 1993, petitioners William Dayag, Edwin Dayag, Eduardo Corton, Edgardo Corton, Leopoldo Naguma, Aloy Flores, and Romeo Punay filed a complaint for illegal dismissal, non-payment of wages, overtime pay, premium pay, holiday pay, service incentive leave, 13th month pay, and actual, moral and exemplary damages against Alfredo Young, a building contractor doing business under the firm name Youngs Construction. They filed the complaint with the National Capital Region Arbitration Branch of the NLRC was subsequently assigned to Labor Arbiter Potenciano Canizares, Jr. Petitioners alleged that they were hired to work as tower crane operators at the latters construction site at Platinum 2000 in San Juan, Metro Manila. In November 1991, they were transferred to Cebu City to work at the construction of his Shoemart Cebu project. On January 30, 1993, William Dayag asked for permission to go to Manila to attend to family matters. He was allowed to do so but was not paid for the period January 23-30, 1993, allegedly due to his accountability for the loss of certain construction tools. Eduardo Corton had earlier left on January 16, 1993, purportedly due to harassment by Young. In February 1993, Edgardo Corton, Aloy Flores and Edwin Dayag also left Cebu for Manila, allegedly for the same reason. Thereafter, petitioners banded together and filed the complaint previously mentioned. Instead of attending the initial hearing set by the labor arbiter, Young filed, on July 6, 1993, a motion to transfer the case to the Regional Arbitration Branch, Region VII of the NLRC. He claimed that the workplace where petitioners were regularly assigned was in Cebu City and that, in consonance with Section 1(a) of Rule IV of the New Rules of Procedure of the NLRC,1 the case should have been filed in Cebu City. Petitioners opposed the same, arguing that all of them, except for Punay, were, by that time, residents of Metro Manila and that they could not afford trips to Cebu City. Besides, they claimed that respondent had its main office at Corinthian Gardens in Quezon City. Young, in reply, declared that the Corinthian Gardens address was not his principal place of business, but actually his residence, which he also used as a correspondent office for his construction firm. Agreeing that petitioners workplace when the cause of action accrued was Cebu City, the labor arbiter, on September 8, 1993, granted Youngs motion and ordered the transmittal of the case to the regional arbitration branch of Region VII. Petitioners promptly appealed said order to the NLRC, which, however, dismissed the same on January 31, 1995, for lack of merit. Citing Nestl Philippines, Inc. vs. NLRC2 and Cruzvale, Inc. vs. Laguesma,3 petitioners moved for a reconsideration of the January 31, 1995 resolution of the Commission. Acting favorably on said motion, the Commission, on August 25, 1995, annulled and set aside its

resolution of January 31, 1995, and remanded the case to the original arbitration branch of the National Capital Region for further proceedings. This prompted Young, in turn, to file his own motion for reconsideration seeking the reversal of the August 25, 1995 resolution of the Commission. Finding the two above-cited cases to be inapplicable to instant case. It reinstated its resolution ordering the transfer to Cebu City. Issue: WON the case should be transferred to Cebu City? Held: No... Young cannot, however, derive comfort from the foregoing, this petition having been overtaken by events. In the recent case of Sulpicio Lines, Inc. vs. NLRC this Court held that the question of venue essentially pertains to the trial and relates more to the convenience of the parties rather than upon the substance and merits of the case. It underscored the fact that the permissive rules underlying provisions on venue are intended to assure convenience for the plaintiff and his witnesses and to promote the ends of justice. With more reason does the principle find applicability in cases involving labor and management because of the doctrine well-entrenched in our jurisdiction that the State shall afford full protection to labor. The Court held that Section 1(a), Rule IV of the NLRC Rules of Procedure on Venue was merely permissive. In its words: This provision is obviously permissive, for the said section uses the word may, allowing a different venue when the interests of substantial justice demand a different one. In any case, as stated earlier, the Constitutional protection accorded to labor is a paramount and compelling factor, provided the venue chosen is not altogether oppressive to the employer.

Aquino vs. National Labor Relations Commission Facts: It appears that petitioner filed before the Labor Arbiter a complaint for illegal dismissal against private respondent (NCR-2-396-87). He alleged that he was removed from the payroll in January 1987 and was not paid his salary. Private respondent answered that petitioner had abandoned his work after he was held accountable for advances amounting to P48,921.94. On May 30, 1990, the Labor Arbiter rendered a decision, finding petitioners dismissal as illegal. It ordered the respondent, Roblett Industrial Construction, Inc., to reinstate the complainant Roman P. Aquino to his former or equivalent position and to pay the backwages. The counsel for private respondent received a copy of the above decision on June 13, 1990. The last day to appeal therefore was on June 23, 1990, which fall on a Saturday. The counsel, however, filed the appeal on Monday, June 25, 1990, two days beyond the reglamentary period. On July 4, 1990, petitioner filed a motion to dismiss the appeal and for the issuance of a writ of execution contending that: a) the time to appeal had already lapsed; and b) Private respondent did not post the surety or cash bond required by Section 223 of the Labor Code, as amended by R.A. No. 6715. Finding that the Labor Arbiter did not abuse his discretion in rendering his decision and that private respondent failed to file a cash or surety bond to perfect its appeal, the NLRC dismissed the appeal in a Resolution dated February 18, 1991. However, upon motion of private respondent, the NLRC set aside the aforementioned resolution in its March 26, 1991 Resolution. On April 22, 1990, petitioner, alleging grave abuse of discretion amounting to lack or excess of jurisdiction on the part of NLRC, filed the instant petition for certiorari under Rule 65 of the Revised Rules of Court. The NLRC, aside from justifying its reversal of the February 18, Resolution, questioned the propriety of the filing of the petition for certiorari. Issue: WON the appeal Should be given due course? Held: No... The NLRC amended its Rules of Procedure to conform with the decision of this Court in Pacaa. As amended, Section 1, Rule VI of the Rules of Procedure of the NLRC now specifies that if the tenth day to perfect an appeal from the decision of the Labor Arbiter to the NLRC falls on a Saturday, the appeal shall be made on the next working day.

To remove any doubts that may possibly arise as a result of the obiter dictum in the cases decided after Pacaa, we hereby reiterate the Pacaaruling and uphold the amendment to Section 1 of Rule VII of the Rules of Procedure of the NLRC enforced on January 14, 1992 on the principle that the law does not require the performance of an impossible act (impossibilum nulla obligatio est). We hold that the filing of the appeal by private respondent on June 25, 1990 was timely. However, while the appeal to the NLRC was filed on time, it must be dismissed for failure of the appellant to file the cash or surety bond required under Article 223 of the Labor Code. The decision of the Labor Arbiter in this case included a monetary award, i.e., award for 3-year back wages amounting to P80,820.00. Therefore, to perfect its appeal before the NLRC, private respondent should have posted a cash or surety bond equivalent to the money judgment in accordance with Article 223 of the Labor Code. In justification of the non-posting of the bond, both respondents argued that the NLRC issued the rules implementing R.A. No. 6715 only on August 31, 1990, which took effect on October 9, 1990. They claimed that the requirement of R.A. No. 6715 on the filing of a bond was not yet in force when private respondent filed its appeal on June 25, 1990. The NLRC further alleged that it was not bound to follow the Interim Rules promulgated by its predecessor because it was the one created under R.A. No. 6715 and authorized to promulgate the implementing rules. We agree with the Solicitor General that the provisions of Article 223 of the Labor Code, as amended by R.A. No. 6715, requiring the posting of cash or surety bond in appeals from decisions of Labor Arbiter granting monetary awards, are selfexecuting and do not need any administrative rules to implement them. The appeal made by private respondent, not having been perfected on time for failure to file the appeal bond, the decision of the Labor Arbiter became final and executory (Filcon Manufacturing Corporation v. NLRC, 199 SCRA 814 [1991]).

NIAConsult, Inc. vs. National Labor Relations Commission Facts: This is a petition for certiorari to annul the order, dated July 21, 1992, and the resolution, dated December 22, 1992, of the National Labor Relations Commission, dismissing petitioners appeal from a decision of the Labor Arbiter on the ground that it had been filed beyond the reglementary period. On July 4, 1990, the Board of Directors of petitioner NIA-Consult, Inc. abolished private respondents position effective August 31, 1990. On August 2, 1990, private respondent Jesus Ocampo filed a complaint alleging illegal dismissal by petitioners. A decision was rendered in his favor on February 15, 1991 by the Labor Arbiter, who ruled that the abolition of private respondents position had been done in bad faith. Accordingly, petitioners were ordered to reinstate private respondent and to pay him backwages and honoraria, as well as damages and attorneys fees. Petitioners appealed to the NLRC on March 11, 1991. It was alleged that counsel received the decision on March 4, 1991. Private respondent filed an answer to the memorandum of appeal, but later moved to dismiss the appeal on the ground that, upon verification, he discovered that the registry return card showed the date of receipt to be March 1, 1991, and not March 4, 1991, as alleged by petitioners in their appeal memorandum. It was further discovered that the receipt of the decision was made on February 25, 1991 as verified by the post office. The motion for reconsideration filed by petitioners was denied. Issue: WON the appeal was seasonably instituted? Held: NO.. As the NLRC observed, the official address given by petitioners former counsel, Atty. Musa I. Maglayang, was c/o NIA Bldg., EDSA, Quezon City. To consider the date of receipt of the decision of the Labor Arbiter to be February 25, 1991, when the decision was delivered at this address, is not to violate the rule (Rule 13, 2) that when a party is represented by counsel, service of process must be made on counsel and not on the party. Petitioners insist, however, that the date of receipt should be considered on March 1, 1991, because a different system of delivery is followed at the NIA. Petitioners explain that under this system, registered mail matter addressed to NIA employees and officers is delivered directly to the NIA Records Section where a personnel would receive the registry return cards without

signing them. The mail matter is delivered personally to the addressees who would then sign the registry return cards. The registry return cards would afterwards be sent back to the post office. Petitioners point out that this is different from the usual practice of the post office of leaving registry notices at the address indicated, which notices the addressee then takes to the post office to claim his mail. Under this procedure, the registry return card is signed at the same time the mail is actually received. In contrast, petitioners claim that under the system followed at NIA, the mail is considered received only upon the addressees signing of the return card, that is, upon personal delivery to the addressee, regardless of the actual date the mail is delivered to the NIA. Petitioners contend that delivery of a copy of the decision in this case to the Records Section was equivalent to the sending of the registry notices but not the actual delivery to a representative of the addressee. The contention is untenable. To allow petitioners to compute the period for appealing in the manner outlined above would be to make the record of receipt of mail at the NIA completely dependent on the date the addressee signs the registry return card, even if the mail, as in this case, has actually been delivered to the NIA much earlier. The rule is that service by registered mail is complete either upon actual receipt by the addressee or at the end of five (5) days, if he does not claim it within five (5) days from the first notice of the postmaster. (Rule 13 8) The purpose is to place the date of receipt of pleadings, judgments and processes beyond the power of the party being served to determine at his pleasure. This purpose would be negated if we were to sanction the procedure allegedly followed by NIA. Petitioners excuse that its counsel, Atty. Maglayang, was out on field work on February 25, 1991 when the decision was received at the NIA and that he actually received the decision only on March 1, 1991 when he signed the registry return card, is not a good reason for departing from the established rule. Moreover, Atty. Maglayang was not the only counsel of NIAConsult, Inc. Atty. Simeon S. Basuil was also counsel for petitioners, to whom the decision could have been delivered if, as claimed, Atty. Maglayang was in the province at the time the mail arrived. At all events, it was the responsibility of petitioners and their counsel to devise a system for the receipt of mail intended for them. (Enriquez v. Bautista, 79 Phil. 220 [1947]; Marquez v. Panganiban, 109 Phil. 1121 [1960]) The finality of a decision is a jurisdictional event which cannot be made to depend on the convenience of a party. Consequently, since the decision of the Labor Arbiter was received by the Records Division of the petitioner NIA on February 25, 1991, the 10-day period within which to file an appeal expired on March 7, 1991 and since petitioners appeal was filed only on March 11, 1991, the appeal was late and the NLRC did not commit a grave abuse of its discretion in dismissing the appeal. This ruling makes it unnecessary for us to pass upon the other issues raised by petitioners.

Garcia vs. National Labor Relations Commission Facts: Sometime in September, 1990, petitioner Rey O. Garcia was hired by private respondent Mahal Kong Pilipinas, Inc. (MKPI) to review and edit articles, news items, literary contributions, essays, manuscripts, and other features to be published in the Say Magazine and other publications owned by private respondent. On March 16, 1992, petitioners employment was terminated. At that time, he was allegedly receiving a monthly salary of Eight Thousand Pesos (P8,000.00). Consequently, petitioner filed a complaint for illegal dismissal against private respondent with the National Labor Relations Commission (NLRC). The private respondent often request the postponement but failed to attend on the prescribed date which prompt the petitioner to move that the private respondent be declared in default and that he be allowed to present his evidence ex parte. On June 15, 1992, private respondent, through a letter from Marilou L. Bocobo, requested Labor Arbiter Nieves V. de Castro for time to answer petitioners allegations. The letter-request, found to be merely dilatory, was denied. On August 13, 1992, Labor Arbiter Nieves V. de Castro rendered a decision against the private respondent, ordering the reinstatement and the payment of backwages of the petitioner. On September 10, 1992, private respondent received a copy of the said decision. However, instead of filing an appeal therefrom, private respondent, through its company president Michael G. say, wrote yet another letter to the labor arbiter expressing surprise and disappointment over an allegedly erroneous decision. However the judgment is already final and executory and writ of execution has been issued pursuant thereof. Subsequently, private respondent filed a motion to quash the writ of execution but the same was not acted upon. On November 25, 1992, private respondent filed a petition for preliminary injunction with respondent NLRC. The NLRC set aside the decision made by de Castro, and that the writ of execution has been quashed. Issue: PUBLIC RESPONDENTS ACTED IN GRAVE ABUSE OF DISCRETION, AMOUNTING TO LACK OF JURISDICTION IN TREATING UNVERIFIED LETTER OF PRIVATE RESPONDENTS CHIEF EXECUTIVE OFFICER, MICHAEL G. SAY, AS AN APPEAL BY SAID RESPONDENT FROM THE DECISION, DATED AUGUST 13, 1992 RENDERED BY LABOR ARBITER NIEVES V. DE CASTRO;

Held: The assignment of errors boils down to the lone issue of whether or not respondent NLRC acted with grave abuse of discretion or in excess of jurisdiction in treating the letter of Michael G. Say as an appeal from the labor arbiters decision of August 13, 1992. We rule that it did. In blatant disregard for the rule mandating strict and rigorous compliance with the reglementary period for appeals, respondent NLRC took cognizance of a mere letter from private respondents president expressing disappointment over what was perceived to be an appalling judgment of Labor Arbiter de Castro and treated said letter as private respondents appeal from the said decision. Clearly therefore, the perfection of an appeal in the manner and within the period prescribed by law is not only mandatory but also jurisdictional. Failure to conform with the rules regarding appeal will certainly render the judgment final and executory, hence, unappealable.

In the case at bar, records bear out that private respondent did not comply with the foregoing mandatory rules on appeals. After receiving a copy of the decision, private respondent through its president, wrote the labor arbiter who rendered the decision and expressed dismay over the judgment. No appeal was taken therefrom within ten (10) days from September 10, 1992, the date private respondent received a copy of such judgment. Neither was a cash or surety bond posted by the private respondent. For even assuming for the sake of argument that the letter is a valid notice of appeal, the lack of a cash or surety bond is fatal to the appeal. The judgment in question involves a monetary award, and in cases where the judgment involves a monetary award, the second paragraph of Article 223 of the Labor Code, as amended by R.A. 6715, provides that the appeal by the employer may be perfected only upon the posting of a cash or surety bond issued by a reputable bonding company duly accredited by the NLRC in the amount equivalent to the monetary award in the judgment appealed from.

UERM-Memorial Medical Center vs. NLRC Facts: The question presented in this petition for certiorari under Rule 65 is whether or not in perfecting an appeal to the National Labor Relations Commission (NLRC) a property bond is excluded by the two forms of appeal bondcash or suretyas enumerated in Article 223 of the Labor Code. The facts show that on 14 December 1987 Republic Act No. 6640 took effect which mandated a ten (P10.00) peso increase on the prevailing daily minimum wage of P54.00. In applying said law, the petitioners granted salary increases to their employees based on the following computation, to wit: a)To members of the faculty who are non-union members, P304.17 per month; b) To rank-and-file employees (individual complainants who are union members), P209.17 per month. There was a difference of P95.00 in the salaries of the two classes of employees. Private respondents who are rank and file employees demanded payment of the difference. Before the parties could settle their dispute, Republic Act No. 6727 took effect on 1 July 1989 which again increased the daily minimum wage in the private sector (whether agricultural or non-agricultural) by P25.00. In compliance, petitioners paid their employees using the following computation, to wit: a)To members of the faculty who are non-union members, P760.42 a month; and b) To rank-and-file employees (individual complainants who are union members), P523.00 a month. Again, there was a difference of P237.42 per month between the salaries of union members and non-union members. In September 1987, petitioners increased the hiring rate of the new employees to P188.00 per month. Private respondents once more demanded from the petitioners payment of the salary differential mandated by RA No. 6727 and correction of the wage distortion brought about by the increase in the hiring rate of new employees. On 12 April 1988, Policy Instruction No. 54 was issued by the then Secretary of Labor Franklin Drilon, stating that the personnel in subject hospitals and clinics are entitled to a full weekly wage of seven days if they have completed the 40-hour/5-day workweek in any given workweek. Petitioners challenged the validity of said Policy Instruction and refused to pay the salaries of the private respondents for Saturdays and Sundays.

Consequently, a complaint was filed by the private respondents, represented by the Federation of Free Workers (FFW), claiming salary differentials under Republic Act Nos. 6640 and 6727, correction of the wage distortion and the payment of salaries for Saturdays and Sundays under Policy Instruction No. 54. which overall amounts reached more than 17million pesos. The NLRC directed petitioners to post a cash or surety bond of P17,082,448.56, however, the petitioner posted a property bond worth P102,345,650. The private respondent moved for the dismissal of the appeal on the ground that Article 223 of the Labor Code, as amended, requires the posting of a cash or surety bond. The NLRC dismissed the appeal by the petitioner. Issue: WON the property bond can be considered for the perfection of an appeal? Held: yes We have given a liberal interpretation to this provision. IN YBL (Your Bus Line) v. NLRC we ruled: x x x that while Article 223 of the Labor Code, as amended by Republic Act No. 6715, requiring a cash or surety bond in the amount equivalent to the monetary award in the judgment appealed from for the appeal to be perfected, may be considered a jurisdictional requirement, nevertheless, adhering to the principle that substantial justice is better served by allowing the appeal on the merits threshed out by the NLRC, the Court finds and so holds that the foregoing requirements of the law should be given a liberal interpretation. We reiterate this policy which stresses the importance of deciding cases on the basis of their substantive merit and not on strict technical rules. In the case at bar, the judgment involved is more than P17 million and its precipitate execution can adversely affect the existence of petitioner medical center. Likewise, the issues involved are not insignificant and they deserve a full discourse by our quasi-judicial and judicial authorities. We are also confident that the real property bond posted by the petitioners sufficiently protects the interests of private respondents should they finally prevail. It is not disputed that the real property offered by petitioners is worth P102,345,650. The judgment in favor of private respondent is only a little more than P17 million.