G.R. No. 131047 March 2, 1999
TOYOTA AUTOPARTS, PHILIPPINES, INC., petitioner, vs. THE DIRECTOR OF THE BUREAU OF LABOR RELATIONS OF THE DEPARTMENT OF LABOR AND EMPLOYMENT, SAMAHANG MANGGAGAWA SA TOYOTA AUTOPARTS, INC., respondents.

FACTS

Samahang Manggagawa sa Toyota Autoparts, Inc. (the Union) applied for and was granted a certificate of registration by the DOLE. Subsequently, the Union filed a petition for certification election. Toyota Autoparts, Inc. (the Company) sought the cancellation of the Union’s registration, alleging fraud and misrepresentation under Article 239(a) of the Labor Code. The Company claimed fourteen employees were deceived into signing union documents, that a signature was forged, and that no organizational meeting was actually held on the date and place stated in the minutes. It further alleged the Union lost the required 20% membership support due to mass withdrawals.
The DOLE Regional Director cancelled the Union’s registration. On appeal, the Director of the Bureau of Labor Relations (BLR) reversed the cancellation. The BLR Director found the employees’ affidavits of deception lacked particularity, gave weight to the dismissal of the forgery complaint, and found the retraction of the union secretary insufficient to disprove the meeting, especially against the uncontroverted affidavits of three union members affirming it. The Company’s motion for reconsideration, supported by affidavits from barangay officials, was denied after the BLR found inconsistencies in these new affidavits. The Company then filed this petition for certiorari.

ISSUE

Whether the Director of the Bureau of Labor Relations committed grave abuse of discretion in reversing the order cancelling the Union’s certificate of registration.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion on the part of the BLR Director. The Court emphasized that certiorari is not a remedy for errors of judgment but only for correcting errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction. The BLR Director, acting within his quasi-judicial authority, meticulously evaluated the conflicting evidence. He found the Company’s evidence—including the affidavits of alleged deceived members, the dismissed forgery complaint, and the retracted statement of the union secretary—to be insufficient to substantiate the charges of fraud. Conversely, he found the Union’s evidence, particularly the affidavits of members attesting to the organizational meeting, to be credible and uncontroverted. The subsequent evaluation of the barangay officials’ affidavits, which revealed inconsistencies, was also within his discretion. The Court ruled that the BLR Director’s factual findings and conclusions were arrived at after a thorough review of the record and were not tainted with arbitrariness, caprice, or personal hostility. Absent a clear showing that his power was exercised in a despotic manner, his decision, even if potentially erroneous, constitutes an exercise of discretion correctible only by appeal, not by certiorari.