GR 168749; (June, 2016) (Digest)
G.R. No. 168749, June 06, 2016
SUGARSTEEL INDUSTRIAL, INC. AND MR. BEN YAPJOCO, PETITIONERS, VS. VICTOR ALBINA, VICENTE UY AND ALEX VELASQUEZ, RESPONDENTS.
FACTS
Respondents Victor Albina, Vicente Uy, and Alex Velasquez were employees of petitioner Sugarsteel Industrial, Inc. On August 16, 1996, a clog-up occurred at the kettle sheet guide during their shift, damaging twenty GI sheets. The company manager, Ben Yapjoco, required them to submit written explanations and subsequently terminated their employment on August 29, 1996, for gross neglect of duty. The respondents filed a complaint for illegal dismissal. The Labor Arbiter ruled the dismissal was justified due to gross negligence but awarded separation pay. On appeal, the NLRC dismissed the respondents’ appeal on a technicality, affirming the Labor Arbiter’s decision for failure to comply with the specific grounds for appeal under Article 223 of the Labor Code.
The respondents then filed a petition for certiorari with the Court of Appeals. The CA granted the petition, finding that the NLRC committed grave abuse of discretion in dismissing the appeal on a mere technicality. The CA proceeded to review the evidence and concluded that the petitioners failed to substantiate the charge of gross and habitual neglect, thereby ruling that the respondents were illegally dismissed. The CA ordered reinstatement with full backwages or separation pay.
ISSUE
Did the Court of Appeals exceed its jurisdiction in a special civil action for certiorari by reviewing the factual findings of the NLRC and deciding the case on its merits?
RULING
No, the Court of Appeals did not exceed its jurisdiction. The Supreme Court affirmed the CA’s decision. While a petition for certiorari under Rule 65 is generally confined to correcting jurisdictional errors, such as acts rendered without jurisdiction or with grave abuse of discretion, the Court has consistently held that the CA is not barred from evaluating the evidence in labor cases when necessary. The CA’s authority to review facts arises precisely when the NLRC’s factual findings are bereft of any support in the records, rendering its decision a nullity due to grave abuse of discretion.
In this case, the NLRC’s affirmance of the Labor Arbiter’s decision was based solely on a technical dismissal of the appeal, without substantively addressing the merits. This constituted a patent disregard of the respondents’ right to due process. The CA correctly determined that this was a grave abuse of discretion, warranting a review of the factual basis of the dismissal. Upon such review, the CA found the evidence insufficient to prove gross negligence, a finding the Supreme Court found no reason to overturn. The CA’s action was a proper exercise of its certiorari powers to correct a capricious and arbitrary exercise of judgment by the NLRC.