G.R. No. 146397; July 1, 2003
COSMOS BOTTLING CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, SERGIO G. REY, SIXTO BATINO, RIZALINO T. TAMONDONG, ROBERTO SANTOS, HERMINIO G. DELA ROSA, EMILIO B. MAGLEO, JOHNNY G. BACANI, ZALDY G. GUZMAN, JONATHAN Y. RELEVO AND IRENEO SOLIS, respondents.

FACTS

Petitioner Cosmos Bottling Corporation dismissed ten of its employees, comprising seven salesmen and three checkers from its San Pedro Plant, on grounds of fraudulent conspiracy and dishonesty. The company alleged their participation in tampering with and falsifying Load Tally Statement Sheets, resulting in unremitted sales proceeds of approximately P130,000.00. The employees denied involvement during the company’s investigation, instead pointing to the plant guards as the responsible parties. The company, however, relied on the statement of a certain Saturnino Montecalvo to effect the terminations.
The dismissed employees filed a complaint for illegal dismissal. The Labor Arbiter ruled in their favor, ordering the payment of separation pay and backwages, a decision subsequently affirmed with a minor modification by the National Labor Relations Commission (NLRC). The NLRC found that the employer failed to substantiate the individual culpability of each employee with substantial evidence, dismissing the charge of “fraudulent conspiracy” as a sweeping allegation insufficient to justify termination. The Court of Appeals later dismissed the company’s petition for certiorari, upholding the NLRC’s findings.

ISSUE

Whether the Court of Appeals committed reversible error in affirming the NLRC’s ruling that the dismissal of the respondents was illegal.

RULING

The Supreme Court DENIED the petition and AFFIRMED the assailed Court of Appeals Decision and Resolution. The Court reiterated the fundamental rule that a petition for review on certiorari under Rule 45 is limited to questions of law. The core issue presented by the petitioner—the factual determination of whether the employees committed dishonesty and fraudulent conspiracy—is decidedly a question of fact. The Court consistently accords finality to the factual findings of quasi-judicial agencies like the NLRC, especially when such findings coincide with those of the Labor Arbiter and are supported by substantial evidence.
The legal logic is anchored on the principle of hierarchy of courts and the specific jurisdictional limits of a Rule 45 petition. The Supreme Court is not a trier of facts. Its role is to review errors of law. The petitioner failed to demonstrate that the factual conclusions of the lower tribunals were devoid of evidentiary support or were based on a gross misapprehension of facts, which are the recognized exceptions allowing a factual review. Consequently, since the petition raised no reviewable question of law and merely sought a re-evaluation of evidentiary facts, it was not cognizable by the Court under the governing procedural rule. The dismissal was thus sustained on procedural grounds, affirming the finding that the employer did not discharge its burden of proving a valid cause for termination.