GR 240084; (September, 2020) (Digest)
G.R. No. 240084 , September 16, 2020
RUBEN O. OLIVEROS AND HOMER HENRY S. SANCHEZ, PETITIONERS, V. THE HON. COURT OF APPEALS, FIRST LAGUNA ELECTRIC COOPERATIVE (FLECO), ET AL., RESPONDENTS.
FACTS
Petitioners Ruben Oliveros and Homer Henry Sanchez were employees of First Laguna Electric Cooperative (FLECO). FLECO received an anonymous text message alleging petitioners owned Sergio Paulo Contractor Services, an accredited contractor of FLECO. FLECO initiated an investigation, issuing memoranda and presenting sworn statements from managers and a housewiring report as evidence. Petitioners denied ownership and argued the evidence was hearsay, claiming no conflict of interest existed as they did not directly contract with FLECO. After a hearing, FLECO terminated petitioners for violating company rules against conflict of interest.
The Labor Arbiter ruled the dismissal illegal due to violation of due process and lack of just cause, ordering reinstatement with backwages and damages. The National Labor Relations Commission (NLRC) reversed this, finding due process was observed and that sufficient evidence established a conflict of interest, noting petitioners’ admitted links to Sergio Paulo’s assets and their supervisory roles in its company profile. Petitioners elevated the case to the Court of Appeals via a Petition for Certiorari under Rule 65.
ISSUE
Whether the Court of Appeals committed grave abuse of discretion in dismissing the Petition for Certiorari on procedural grounds.
RULING
No, the Court of Appeals did not commit grave abuse of discretion. The Supreme Court emphasized that a writ of certiorari under Rule 65 is an extraordinary remedy, strictly governed by procedural rules. The CA correctly dismissed the petition for petitioners’ failure to comply with the requirement under Section 3, Rule 46 of the Rules of Court to submit material portions of the record, such as the NLRC decision and motion for reconsideration, which are indispensable for a proper review. Despite being granted an extension, petitioners submitted only additional annexes, not the core documents.
The Supreme Court clarified that the special civil action of certiorari is not a substitute for a lost appeal. Petitioners’ recourse from the NLRC decision was a Petition for Review under Rule 45, not a Petition for Certiorari under Rule 65. The NLRC decision is final and executory, and any error in its factual or legal appreciation is an error of judgment, not jurisdiction. A Rule 65 petition is available only for jurisdictional errors or grave abuse of discretion amounting to lack of jurisdiction. The NLRC’s evaluation of evidence and conclusion on the existence of just cause for dismissal fall within its jurisdiction and do not constitute grave abuse. Therefore, the CA’s dismissal on both procedural and substantive grounds was proper.