G.R. No. L-46732 May 5, 1979
MARIO Z. REYES, petitioner, vs. HON. RONALDO B. ZAMORA as Presidential Assistant for Legal Affairs, Office of the President, MARSMAN and Co., Inc., and E.G. VITO, respondents.

FACTS

Petitioner Mario Z. Reyes, Credit and Collection Manager of Marsman and Co., Inc., was preventively suspended on January 17, 1974, for alleged misappropriation of a P4,000 portion of a P24,000 prize check issued to a contest winner, Evangeline Tagulao. The company based its action on two handwritten letters from Tagulao claiming she received only P20,000. Subsequently, Tagulao retracted her statements in two later letters, asserting she received the full P24,000 and returned the company’s compensatory P4,000 check. Reyes filed a complaint for illegal dismissal. After mediation and fact-finding, the mediator recommended reinstatement with back wages, a recommendation affirmed by the Secretary of Labor. The company appealed to the Office of the President, which reversed the Labor Secretary’s decision and granted the company clearance to terminate Reyes’s employment. Reyes then filed this special civil action for certiorari and mandamus.
The petition challenges the Office of the President’s decision, arguing it was rendered without jurisdiction and with grave abuse of discretion. Reyes contends the Office of the President reviewed the case de novo, considering evidence not presented during the mediation-fact-finding stage before the National Labor Relations Commission (NLRC), thereby violating procedural due process. He seeks annulment of the decision and an order for the Office of the President to limit its review to the evidence established in the original proceedings.

ISSUE

Whether the Office of the President acted without or in excess of jurisdiction or with grave abuse of discretion in reviewing the Secretary of Labor’s decision on appeal and in reversing the same based on evidence not formally presented in the original proceedings.

RULING

The Supreme Court granted the petition, annulled the decision of the Office of the President, and reinstated the decision of the Secretary of Labor. The Court held that the Office of the President committed grave abuse of discretion. While the President, under the police power, retains ultimate authority over labor cases involving national interest, the exercise of such power must conform to fundamental procedural due process. The records revealed that the Office of the President’s reversal was predicated on a de novo evaluation, considering affidavits and documents not offered or admitted as evidence during the mediation-fact-finding hearings before the NLRC. This procedural misstep deprived the petitioner of his right to confront and rebut this new evidence, violating the essence of a fair hearing.
The legal logic is anchored on the principle that appellate review, even by the highest executive authority, must be grounded on the evidence of record from the proceedings below. The Court emphasized that the factual findings of the Secretary of Labor, supported by substantial evidence from the original hearings—particularly the retraction letters of the key witness, Tagulao—should have been accorded respect. By disregarding this record and basing its decision on extrinsic evidence, the Office of the President acted arbitrarily. Its decision was not merely an error of judgment but a capricious and whimsical exercise of power amounting to a denial of due process, which is correctible by certiorari. Consequently, the Secretary of Labor’s order for reinstatement with back wages was reinstated.