G.R. No. L-15190; May 30, 1961
PHILIPPINE PLYWOOD CORPORATION, petitioner, vs. NATIONAL LABOR UNION, respondent.

FACTS

In August 1950, Philippine Plywood Corporation dismissed thirty-seven employees. The Corporation claimed the dismissals were for just cause. The affected employees, through the National Labor Union, filed a case before the Court of Industrial Relations (CIR), docketed as Case No. 553-V. After a full hearing, the CIR, in a decision dated October 22, 1958, found that most of the employees were dismissed without just cause. The CIR ordered their reinstatement with varying awards of back wages, minus earnings elsewhere, while upholding the dismissal of a few others. The Corporation’s motion for reconsideration was denied by the CIR en banc.
The Corporation filed a petition with the Supreme Court, styling it as both a special civil action for certiorari and an appeal by certiorari. It alleged the CIR gravely abused its discretion in its factual findings and conclusions. The Supreme Court noted that the Corporation’s notice of appeal was filed forty days after the CIR’s resolution, far beyond the ten-day period prescribed by law for an appeal by certiorari under Commonwealth Act No. 103 .

ISSUE

Whether the Court of Industrial Relations committed a grave abuse of discretion in its factual determination that the employees were dismissed without just cause, warranting the grant of the special civil action of certiorari.

RULING

The petition is dismissed. The Supreme Court held that the case could only be treated as a special civil action for certiorari, as the appeal was filed out of time. For certiorari to lie, the petitioner must demonstrate that the tribunal acted without or in excess of jurisdiction or with grave abuse of discretion. The Court found no such abuse.
The CIR unquestionably had jurisdiction over the labor dispute. Its task was to evaluate the evidence presented by both parties on the validity of the dismissals. After a meticulous review of the evidence, detailed in a 58-page decision, the CIR concluded the employees’ evidence was more credible. It found the dismissals were motivated because the employees were involved in an administrative complaint against the Corporation’s General Manager for various irregularities, not for the alleged just causes. The Supreme Court affirmed that a mere error in judgment or an evaluation of evidence, absent a showing of capricious or whimsical exercise of judgment, does not constitute grave abuse of discretion. The Corporation’s failure to timely avail of the remedy of appeal by certiorari, which was plain and adequate, further barred relief.
The Court found the CIR’s conclusions supported by the record. It highlighted the suspicious timing of the mass dismissals shortly after the complaint against the General Manager and the lack of explanation for not acting sooner on the alleged infractions. Evidence also refuted the claim of a production slowdown, attributing low output to factors like insufficient log supply and rainy weather. Thus, the CIR committed no grave abuse of discretion in its factual findings and award.