New 15-day rule for appeals from VA to CA

For many years, it has been thought by authors in labor relations law that an appeal to the Voluntary Arbitrator (VA) to the Court of Appeals (CA) under Rule 43 must be done within ten (10) days set by the Labor Code, instead of the fifteen (15) days fixed under the Rules of Court. The explanation has been that substantive law prevails over procedural law.

However, in the recent case of GNC vs. CA (G.R. No. 188492), it was held that a petition for review before the CA from the VA must be filed within 15 days from notice under Section 4 of Rule 43 of the Rules of Court. The 10-day period under the Labor Code merely applies to a motion for reconsideration (MR) filed before the VA. Below is the full text of the case.