G.R. No. 230112 , May 11, 2021
GLOBAL MEDICAL CENTER OF LAGUNA, INC., PETITIONER, VS. ROSS SYSTEMS INTERNATIONAL, INC., RESPONDENT.

FACTS

This case involves a Separate Opinion by Justice Leonen concurring with the ponencia of Justice Caguioa in consolidated cases concerning the extent of judicial review of arbitral awards from the Construction Industry Arbitration Commission (CIAC). The opinion is written to amplify points from prior decisions, including CE Construction Corporation v. Araneta Center, Inc., and to advocate for a decisive harmonization of the laws on CIAC review. The CIAC was created by Executive Order No. 1008 (Construction Industry Arbitration Law) to enable early and expeditious settlement of construction disputes, recognizing construction’s role in national development. Its jurisdiction and the finality of its decisions are outlined in the law, which has been validated and incorporated by subsequent acts of Congress, including Republic Act No. 9184 (Government Procurement Reform Act) and Republic Act No. 9285 (Alternative Dispute Resolution Act of 2004).

ISSUE

The central issue addressed in the Separate Opinion is the proper scope and mode of judicial review over factual findings and awards rendered by CIAC arbitral tribunals.

RULING

The Separate Opinion concurs with the ponencia and rules as follows:
1. An immense degree of deference is due to the factual findings of CIAC arbitral tribunals. Appeals from CIAC rulings may only be entertained on pure questions of law and only before the Supreme Court, as stipulated by Executive Order No. 1008.
2. Rule 43 of the 1997 Rules of Civil Procedure is mistaken in allowing appeals from CIAC awards to the Court of Appeals, as it is a procedural rule ill-equipped to vest jurisdiction contrary to the substantive law.
3. However, CIAC arbitral tribunals’ factual findings are not entirely beyond judicial review. The constitutionally-enshrined power to review acts for grave abuse of discretion amounting to lack or excess of jurisdiction allows factual findings to be examined through a petition for certiorari under Rule 65, over which the Court of Appeals has jurisdiction.
4. The review under Rule 65 must be extraordinarily narrow. The Court of Appeals can review factual findings only in two instances: (a) when the integrity of the arbitral tribunal itself has been put in jeopardy, as contemplated in Section 24 of Republic Act No. 876 (the Arbitration Law); or (b) when there is grave abuse of discretion made by way of a violation of the Constitution or laws. Review on any other ground is excessive and invalid.
5. The CIAC is a statutory creation with distinctive competence in construction disputes, and its arbitral tribunals are quasi-judicial bodies whose factual determinations are generally final and binding. The policy of the law favors arbitration, and judicial review should respect the autonomy and authority of the arbitral process.