GR 116419; (February, 1996) (Digest)
G.R. No. 116419 ; February 9, 1996
MAURICE C. FLORES, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION and PREMIERE DEVELOPMENT BANK, represented by PROCOPIO C. REYES, JR., respondents.
FACTS
Petitioner Maurice C. Flores was employed by Premiere Development Bank on a six-month probationary status as a loan processor. Her performance was evaluated monthly, with the results determining her eligibility for permanent employment. The monthly evaluations consistently noted deficiencies, particularly in communication skills and effectiveness in interviews. In the final month of her probation, while assigned as a Department Secretary, her supervisor’s evaluation cited a need for more sophistication in phone calls and appearance, tolerable qualities, and a need to improve spelling and common sense. On September 23, 1992, prior to the lapse of the probationary period, the bank notified her that her employment was automatically terminated for failure to meet its reasonable standards.
Flores filed a complaint for illegal dismissal. The Labor Arbiter ruled in her favor, declaring her a regular employee and ordering reinstatement with backwages. The arbiter held that her functions as loan processor/secretary made her a regular employee and that she was allowed to work beyond the probationary period. On appeal, the National Labor Relations Commission (NLRC) reversed the arbiter’s decision, finding the termination lawful and valid. The NLRC held she remained a probationary employee validly terminated for failing to meet performance standards, and it found her evidence of working beyond probation to be altered.
ISSUE
Whether the Supreme Court can review the NLRC’s factual findings and evaluation of evidence through a petition for certiorari under Rule 65.
RULING
The Supreme Court dismissed the petition, upholding the NLRC’s decision. The Court emphasized that the petition was a special civil action for certiorari under Rule 65, an extraordinary remedy limited to correcting errors of jurisdiction or grave abuse of discretion amounting to lack of jurisdiction. It is not a tool for re-evaluating the sufficiency of evidence or factual findings, which are generally accorded finality. The Court found no jurisdictional error or grave abuse of discretion by the NLRC.
The NLRC’s factual conclusions were supported by substantial evidence. First, the labor arbiter’s finding that Flores became a regular employee due to her functions was a legal non sequitur; the nature of her duties did not automatically confer regular status. Second, the claim that she worked beyond probation was correctly rejected by the NLRC after a careful examination revealed alterations and inconsistencies in her submitted work records, making it plausible that termination occurred on September 23, 1992, as notified. Thus, as a probationary employee validly terminated for failing to meet reasonable performance standards before the probation period ended, her dismissal was lawful.