G.R. No. 230112 & 230119, May 11, 2021
GLOBAL MEDICAL CENTER OF LAGUNA, INC., PETITIONER, VS. ROSS SYSTEMS INTERNATIONAL, INC., RESPONDENT. [G.R. No. 230119] ROSS SYSTEMS INTERNATIONAL, INC., PETITIONER, VS. GLOBAL MEDICAL CENTER OF LAGUNA, INC., RESPONDENT.

FACTS

This case involves a dispute over a CIAC arbitral award. The main Decision, penned by Justice Caguioa, reinstated the CIAC’s arbitral award with a modification directing Global Medical Center to furnish Ross Systems with a BIR Form No. 2307. The ponencia also established a rule of prospective application outlining two modes for judicial review of CIAC arbitral awards: (1) a direct appeal to the Supreme Court via Rule 45 on pure questions of law, and (2) an original special civil action for certiorari to the Court of Appeals under Rule 65 on the ground of grave abuse of discretion.

ISSUE

Whether the ponencia’s proposed contraction/qualification of the “grave abuse of discretion” ground under Rule 65 for reviewing CIAC arbitral awards—limiting it to (1) a challenge on the integrity of the arbitral tribunal (e.g., fraud, corruption, evident partiality) and (2) an allegation of the tribunal’s violation of the Constitution or positive law—is justified and consistent with law and jurisprudence.

RULING

In her Separate Concurring and Dissenting Opinion, Justice Perlas-Bernabe agrees with the ponencia’s disposition to reinstate the modified CIAC award and the establishment of the two prospective modes of judicial review. However, she dissents from and expresses reservations against the ponencia’s discussion seeking to contract the scope of “grave abuse of discretion” under Rule 65 for CIAC awards.
Justice Perlas-Bernabe argues that while the concept of grave abuse of discretion can be flexible, any contraction or qualification of it must be justified by a clear constitutional or statutory basis. She finds no such basis in the pertinent laws—Executive Order No. 1008, Republic Act No. 876 (The Arbitration Law), and RA 9285 (The Alternative Dispute Resolution Act of 2004)—to warrant limiting Rule 65 review exclusively to challenges against the “integrity of the arbitral tribunal,” a term which collectively refers to the grounds for vacating an award under Section 24 of RA 876 (e.g., corruption, fraud, evident partiality, misconduct, excess of power).
She notes an inconsistency in the ponencia: while it initially proposes to contract grave abuse to the “integrity” grounds, it ultimately recognizes that a violation of the Constitution or positive law is also a proper ground for Rule 65 review. This recognition, she points out, already goes beyond the exclusive ambit of Section 24 of RA 876. Therefore, the proposed contraction into the narrower “integrity of the arbitral tribunal” qualification is rendered unnecessary and lacks legal foundation. She maintains that the grounds under Section 24 of RA 876 should be treated as prototypical examples, not as the exclusive grounds, for a Rule 65 petition against a CIAC award, to avoid excluding other permissible jurisdictional errors.