Short answer. No. Rule 43, Section 2 expressly excludes judgments or final orders issued under the Labor Code from its coverage, so labor rulings cannot be brought to the Court of Appeals through the Rule 43 petition for review procedure that governs most other quasi-judicial agencies.
What the law says
This Rule shall not apply to judgments or final orders issued under the Labor Code of Philippines.
Rule 43, Section 2 — Cases not covered. Read the full provision →
A narrow but important carve-out
Rule 43 otherwise covers a wide sweep of quasi-judicial agencies, but Section 2 draws one clear line: this Rule shall not apply to judgments or final orders issued under the Labor Code of Philippines. That single sentence removes an entire category of disputes — labor and employment rulings — from the procedure that governs everything from Civil Service Commission cases to Board of Investments rulings, carving out a clean exception rather than leaving the boundary ambiguous. A litigant surprised to find their labor case excluded from Rule 43 should look instead to the specific review procedure that Philippine labor law and jurisprudence actually prescribe for NLRC rulings.
Why labor rulings sit outside Rule 43
Labor adjudication follows its own statutory framework, with its own tribunals, timelines, and internal review layers before a case could even reach the appellate courts. Folding labor rulings into the general Rule 43 petition for review would have collapsed that distinct structure into a procedure designed for other kinds of administrative bodies, so the drafters excluded it outright rather than leave the boundary to be worked out case by case through litigation. Preserving that separate labor-specific track also respects the specialized expertise labor tribunals are meant to bring to employment disputes.
What this means in practice
Before filing any petition for review with the Court of Appeals against an agency ruling, check the source of the decision. If it was issued under the Labor Code, Rule 43 simply does not apply, and a party who files under it anyway risks having the petition rejected as brought under the wrong procedure — a costly mistake if it happens near the end of the filing period, since correcting course afterward may already be too late. Confirming the source of the ruling before choosing a procedural vehicle is a basic but essential first step in any appeal from an administrative body.
How narrow the exclusion actually is
Section 2 excludes only judgments or final orders issued under the Labor Code — it does not exclude every agency that happens to touch employment matters, and it leaves every other quasi-judicial body Rule 43 otherwise covers untouched. The exclusion binds both the Court of Appeals, which must decline to treat a labor ruling as a proper Rule 43 petition, and the appellant, who bears the burden of routing the case correctly in the first place. The practical consequence of getting this wrong is significant: filing a Rule 43 petition against a labor ruling does not merely misfire procedurally, it can also mean the deadline for the correct remedy runs out while the improper petition is pending, since an improper filing generally does not toll the period for the right one.
Related provisions
- Rule 43, Section 2 — Cases not covered
- Rule 43, Section 1 — Scope
- Rule 43, Section 3 — Where to appeal