G.R. No. L-25291. March 10, 1977.
THE INSULAR LIFE ASSURANCE CO., LTD. EMPLOYEES ASSOCIATION-NATU, FGU INSURANCE GROUP WORKER & EMPLOYEES ASSOCIATION-NATU, and INSULAR LIFE BUILDING EMPLOYEES ASSOCIATION, petitioners, vs. THE INSULAR LIFE ASSURANCE CO., LTD., FGU INSURANCE GROUP, JOSE M. OLBES AND COURT OF INDUSTRIAL RELATIONS, respondents.

FACTS

This is a resolution on a motion for reconsideration filed by the respondents, Insular Life Assurance Co., Ltd., FGU Insurance Group, and Jose M. Olbes, seeking a re-examination of the Supreme Court’s decision dated January 30, 1971. The respondents primarily challenge the Supreme Court’s review and reversal of the factual findings made by the Court of Industrial Relations (CIR). They argue that the Court disregarded voluminous documentary and testimonial evidence they presented, which included numerous exhibits and the testimonies of several witnesses. The respondents contend that the CIR’s factual determinations, being supported by substantial evidence, are binding on the Supreme Court.
The core dispute stems from a labor conflict involving unfair labor practice allegations. The petitioners, labor unions, had raised issues concerning union security, the filing of criminal charges against strikers, and the companies’ conduct during negotiations and strikes. The CIR had ruled in favor of the respondents, but the Supreme Court, in its January 1971 decision, reversed the CIR, finding its conclusions unsupported by substantial and credible evidence. The respondents now enumerate specific factual findings by the Supreme Court which they claim are either without basis in the record or contrary to the evidence presented.

ISSUE

Whether the Supreme Court erred in reviewing and reversing the factual findings of the Court of Industrial Relations, given the doctrine that such findings are binding if supported by substantial evidence.

RULING

The Supreme Court denied the motion for reconsideration, reaffirming its authority to review the CIR’s factual findings. The Court clarified that while the rule of substantial evidence governs the CIR, and its findings are generally binding if so supported, this principle is not absolute. The Court retains the power to review such findings when they are not supported by substantial and credible evidence. Substantial evidence is defined as such relevant evidence as a reasonable mind might accept as adequate to support a conclusion, and it must be credible both quantitatively and qualitatively.
The Court held that in this case, a review of the entire factual milieu was necessary because the CIR’s findings lacked the requisite substantial and credible proof. The Court addressed the respondents’ grouped objections, which pertained to findings allegedly without record basis, contrary to the CIR’s determination, or relating to unassigned errors. While the Court conceded one minor point regarding a specific circular, it found the respondents’ other objections to be without merit, often based on a misimpression of the Court’s statements. The Court emphasized that its earlier decision was grounded on a reasonable assessment of the circumstances revealed by the record, which justified the reversal of the CIR’s unsupported conclusions. The resolution ultimately underscores the Supreme Court’s supervisory role in ensuring that industrial relations decisions are anchored on credible and substantial evidence.