GR 130866; (September, 1998) (Digest)
G.R. No. 130866 September 16, 1998
ST. MARTIN FUNERAL HOME, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and BIENVENIDO ARICAYOS, respondents.
FACTS
Private respondent Bienvenido Aricayos filed a complaint for illegal dismissal against St. Martin Funeral Home. He alleged he was employed as Operations Manager starting February 6, 1995, but was dismissed on January 22, 1996 for allegedly misappropriating funds. The petitioner, St. Martin Funeral Home, countered that Aricayos was not an employee but a relative who voluntarily assisted in the business out of gratitude for financial help. The labor arbiter dismissed the case for lack of jurisdiction, ruling no employer-employee relationship existed. On appeal, the NLRC set aside the arbiter’s decision and remanded the case for further proceedings. St. Martin then filed this petition for certiorari directly with the Supreme Court, alleging the NLRC committed grave abuse of discretion.
ISSUE
Whether the Supreme Court can directly entertain a petition for certiorari assailing a decision of the National Labor Relations Commission.
RULING
No. The Supreme Court ruled that petitions for certiorari from NLRC decisions must be filed with the Court of Appeals, not directly with the Supreme Court. The legal logic is anchored on the hierarchy of courts and the provisions of Batas Pambansa Blg. 129, as amended by Republic Act No. 7902 . This law expanded the jurisdiction of the Court of Appeals, granting it exclusive original jurisdiction over actions for certiorari against quasi-judicial agencies like the NLRC, provided no appeal is available. The Court emphasized that while no statutory appeal from NLRC decisions exists, the special civil action of certiorari under Rule 65 remains the proper remedy to review NLRC decisions for grave abuse of discretion. However, this remedy must be filed with the Court of Appeals, which is the appropriate forum for reviewing factual determinations. Direct resort to the Supreme Court is improper and violates the doctrine of hierarchy of courts, as the High Court is not a trier of facts. Consequently, the petition was remanded to the Court of Appeals for proper disposition.