GR 145855; (November, 2004) (Digest)
G.R. No. 145855 November 24, 2004
Pepsi-Cola Products Philippines, Inc., petitioner, vs. The Court of Appeals, and Pepsi-Cola Products Philippines, Inc. Employees & Workers Union (UOEF No. 70) represented by its incumbent president, Isidro Realista, respondents.
FACTS
Pepsi-Cola Products Philippines, Inc. Employees and Workers Union (PCEWU) filed a complaint against Pepsi-Cola Distributors of the Philippines (PCDP) for overtime pay for services rendered by 53 members on eight designated Muslim holidays in 1985. The employees were assigned in Iligan City, Tubod, Lanao del Norte, and Dipolog City. The union claimed they were previously paid for such work and submitted a certification from the Regional Autonomous Government listing the holidays.
PCDP countered that only five Muslim holidays were legal under Presidential Decree No. 1083, that Dipolog City was not an area officially observing these holidays, and that such benefits applied only to Muslim employees, not all workers in the area. The Executive Labor Arbiter ruled in favor of the union, ordering payment. The National Labor Relations Commission (NLRC) initially affirmed but later dismissed the entire case for lack of jurisdiction, claiming the appeal was filed out of time. The Court of Appeals set aside the NLRC’s dismissal and reinstated the Labor Arbiter’s decision.
ISSUE
Whether the Court of Appeals committed reversible error in reinstating the Executive Labor Arbiter’s decision on the merits after nullifying the NLRC’s dismissal order.
RULING
The Supreme Court partially granted the petition. It held that the NLRC’s dismissal of the case for alleged lack of jurisdiction was a patent nullity, as the appeal was timely filed. However, the Court of Appeals exceeded its jurisdiction under Rule 65 of the Rules of Court when it proceeded to reinstate the Labor Arbiter’s decision on the merits. The proper scope of certiorari is to correct errors of jurisdiction, not errors of judgment. By nullifying the NLRC’s dismissal resolution, the CA’s authority was limited to ordering the reinstatement of the case before the NLRC for it to resolve the pending motions for reconsideration on the merits. The CA’s decision to directly reinstate the Labor Arbiter’s award was void for lack of statutory authority. Consequently, the Supreme Court modified the CA decision, affirming the nullification of the NLRC’s dismissal but directing the NLRC to resolve the pending motions with dispatch.