G.R. No. L-76001, September 5, 1988
Producers Bank of the Philippines, petitioner, vs. The National Labor Relations Commission, Producers Bank Employees Association, Eleuterio Yap, Ferdinand Lazo, Robert Tan, Alberto Brillo, Frederick Cases, Marilou Villena, and Arlene Villaro, respondents.

FACTS

The petitioner, Producers Bank of the Philippines, dismissed several employees for allegedly committing illegal acts during a strike on October 1, 1984. The Labor Arbiter, Virginia Son, found the strike illegal and attended by violence, coercion, intimidation, and destruction of property. Consequently, the Labor Arbiter upheld the dismissals. On appeal, the National Labor Relations Commission (NLRC) modified this decision. While agreeing the strike was illegal, the NLRC found that the specific acts of “coercive picketing” attributed to the individual private respondents (Yap, et al.) did not warrant the extreme penalty of dismissal. The NLRC thus ordered their immediate reinstatement.
The bank filed a petition for review with the Supreme Court, which was initially dismissed. The Court held the petition raised factual issues and found no showing that the NLRC’s findings were unsupported by substantial evidence or that it acted with grave abuse of discretion. The bank then filed this motion for reconsideration, arguing the NLRC exceeded its jurisdiction.

ISSUE

Whether the National Labor Relations Commission acted with grave abuse of discretion in modifying the Labor Arbiter’s decision and ordering the reinstatement of the dismissed employees.

RULING

The Supreme Court denied the motion for reconsideration, holding that the NLRC did not commit grave abuse of discretion. The Court reiterated the settled doctrine that factual findings of quasi-judicial agencies like the NLRC are accorded great respect and finality, provided they are supported by substantial evidence. The Court defined grave abuse of discretion as a capricious, whimsical, or arbitrary exercise of judgment equivalent to lack of jurisdiction, which was not present here.
The petitioner’s argument that the NLRC violated Article 264(e) of the Labor Code, which prohibits acts of violence during picketing, was insufficient. The NLRC, in the exercise of its appellate jurisdiction, made a distinct factual determination differentiating the degree of culpability of the individual respondents from other strikers. Its conclusion that coercive picketing alone did not justify dismissal, despite the overall illegal strike, was within its discretionary power to assess the evidence and impose appropriate penalties. The Court found no patent arbitrariness in this assessment. Since the NLRC’s decision was supported by substantial evidence and not tainted by arbitrariness, its modification of the Labor Arbiter’s ruling was a valid exercise of its authority, not an evasion of a positive legal duty.