G.R. No. L-70544 November 5, 1987
Gelmart Industries (Phils.), Inc., petitioner, vs. Hon. Vicente Leogardo, Jr., in his capacity as Deputy Minister of Labor and Employment, Francisco Estrella, as the then Regional Director of MOLE Region No. IV, and Jenny P. Juanillo, respondents.

FACTS

Petitioner Gelmart Industries had a collective bargaining agreement with the union GATCORD. On August 1, 1977, GATCORD went on strike. The Ministry of Labor issued a return-to-work order with a 48-hour deadline. All workers complied except 334, including private respondent Jenny Juanillo. Gelmart applied for clearance to terminate these workers. Deputy Minister Leogardo, by order dated October 5, 1977, sustained the preventive suspension but certified the termination issue for compulsory arbitration before the NLRC. In a decision dated September 13, 1978, the labor arbiter granted clearance for dismissal but ordered the reinstatement of workers who did not participate in the strike due to justifiable causes like illness or validated absences. A list of those ordered reinstated was included; Juanillo’s name was not on this list.
Subsequently, on February 15, 1979, Juanillo filed a separate complaint for illegal dismissal, claiming she was on approved vacation leave from August 1 to 7, 1977, and thus could not have participated in the strike. She alleged she was refused work upon her return on August 8, 1977. The Regional Director ruled in her favor, ordering reinstatement with full backwages, a decision affirmed by Deputy Minister Leogardo. Gelmart filed this certiorari petition, arguing the complaint was barred by the prior final NLRC decision and that the order was unsupported by substantial evidence.

ISSUE

Whether public respondents committed grave abuse of discretion in ruling for Juanillo’s reinstatement despite a prior final NLRC decision on the termination issue and in finding her dismissal illegal based on insufficient evidence.

RULING

Yes. The Supreme Court granted the petition and reversed the orders of the public respondents. The Court held that Juanillo’s separate complaint was effectively barred by the final and executory decision in the compulsory arbitration case (NLRC RB-IV-13275-77), which conclusively ruled on the termination of the workers who failed to return to work. As a union member, her claim should have been ventilated in those proceedings, especially since the arbitral decision specifically provided for the reinstatement of workers with validated absences. Her failure to present her leave claim during that arbitration precluded her from raising it in a subsequent action.
Moreover, the Court found no substantial evidence to support Juanillo’s claim of an approved leave. Her sole evidence was a self-serving, unverified letter requesting leave, with no proof of its receipt by the company. This quantum of evidence fails to meet the requirement of substantial evidence—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion—necessary in administrative adjudication. Public respondents therefore acted with grave abuse of discretion in disregarding the final NLRC judgment and in basing their decision on insufficient evidence.