GR 78591; (March, 1989) (Digest)
G.R. No. 78591 March 21, 1989
PURE FOODS CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, REMIGIO CLAVIO, ANDRES CATUBAY, VIRGILIO UMALI, ORLANDO REY and JORGE DEL ROSARIO, respondents.
FACTS
Private respondents were employees of Pure Foods Corporation in various capacities: drivers, a utility man, a delivery man, and a checker. On March 17, 1981, an incident occurred where a delivery truck was found to be overweight by 20 kilos during the weighing process. Following this, all private respondents were indefinitely suspended on March 18, 1981, for alleged involvement in pilferage, without a prior investigation. Their suspension continued until they were eventually dismissed without the required notice or clearance from the Ministry of Labor.
The labor arbiter found the dismissals illegal, ordering reinstatement and payment of backwages. The National Labor Relations Commission (NLRC) affirmed this decision but modified the award of backwages. Pure Foods Corporation filed this petition for certiorari, arguing that the NLRC committed grave abuse of discretion in finding the dismissals illegal and in ordering reinstatement.
ISSUE
Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the labor arbiter’s decision that the dismissal of the private respondents was illegal due to lack of substantial evidence.
RULING
The Supreme Court dismissed the petition, affirming the NLRC’s decision. The legal logic centers on the burden of proof in termination cases and the standard of judicial review in certiorari. In termination for cause, the employer bears the burden of proving by substantial evidence that the dismissal was for a just or authorized cause. The Court found that Pure Foods failed to discharge this burden. The evidence presented—primarily affidavits from security guards—was deemed insufficient, unreliable, and contradictory. Notably, the affidavits were identical in form except for minor details, and the alleged eyewitness account was inconsistent with the investigation report. The Court agreed with the Solicitor General’s observation that sustaining the petitioner would require speculation, as there was no clear, positive, and convincing evidence of the employees’ guilt.
Furthermore, the Court clarified the limited scope of certiorari. Such a writ rectifies only errors of jurisdiction, not errors of judgment. The findings of fact by quasi-judicial agencies like the NLRC, when supported by substantial evidence, are accorded respect and finality. Here, the NLRC’s conclusion that the dismissals were illegal was firmly grounded on the evidentiary record, showing no arbitrariness or disregard of evidence that would constitute grave abuse of discretion. Consequently, the orders for reinstatement (or separation pay if reinstatement is not feasible) and payment of backwages were upheld as legally sound.