Sugarsteel Industrial Inc. vs. Albina, G.R. No. 168749, 06 June 2016.

BERSAMIN, J.

Facts: Respondents Albina together with other Uy and Velasquez alleged that they
were illegally dismissed by petitioner Sugarsteel Industrial Inc. In the decision
rendered by the Labor Arbiter, it ruled against respondents and stated that the
dismissal was justified but petitioners should pay them their separation pay. On
appeal, NLRC ruled against respondents for failure to comply with Article 223 of the
Labor Code. NLRC ruled that respondents ground: "the decision with all due respect,
is not supported by evidence and is contrary to the facts obtaining" is not one of
those listed under Art 223.

Art. 223. Appeal - Decisions, awards, or orders of the Labor Arbiter are
final and executory unless appealed to the Commission by any or both
parties within ten (10) calendar days from receipt of such decisions, awards,
or orders. Such appeal may be entertained only on any of the following
grounds:

(a) If there is prima facie evidence of abuse of discretion on the part of the
Labor Arbiter;

(b) If the decision, order or award was secured through fraud or coercion,
including graft and corruption;

(c) If made purely on questions of law; and

(d) If serious errors in the findings of facts are raised which would cause
grave or irreparable damage or injury to the appellant.

x x x x.

CA ruled in favor of respondents in their petition for certiorari and stated that
the NLRCs affirmance of the Labor Arbiters decision did not accord with the
evidence on record and the applicable law and jurisprudence and that based on its
review, the respondents were illegally dismissed since the company failed to establish
gross and habitual neglect.

Petitioner company now contends that CA gravely abused its discretion by

disregarding the factual findings of the Labor Arbiter and that CA exceeded its
jurisdiction in making its own findings after re-assessing the facts and the sufficiency
of the evidence presented to the Labor Arbiter.

Issue: Did the CA exceeded its jurisdiction?

Ruling: No. CA did not exceed its jurisdiction by reviewing the evidence and deciding
the case on the merits despite the judgment of the NLRC already being final.
The Court in past jurisprudence, have expounded the competence of CA in certiorari
cases to review the factual findings of NLRC. Should the CA annul the decision of
the NLRC upon its finding of jurisdictional error on the part of the latter, then it has
the power to fully lay down whatever the latter should have decreed. The judicial
function of the CA in the exercise of its certiorari jurisdiction over the NLRC extends
to the careful review of the NLRC's evaluation of the evidence because the factual
findings of the NLRC are accorded great respect and finality only when they rest on
substantial evidence. Accordingly, the CA is not to be restrained from revising or
correcting such factual findings whenever warranted by the circumstances simply
because the NLRC is not infallible. Indeed, to deny to the CA this power is to
diminish its corrective jurisdiction through the writ of certiorari.

In this case, CA acted judiciously in undoing the too literal interpretation of Article
223 of the Labor Code by the NLRC. The enumeration in the provision of the
grounds for an appeal actually encompassed the ground relied upon by the
respondents in their appeal. Their phrasing of the ground, albeit not hewing closely
(or literally) to that of Article 223, related to the first and the last grounds under the
provision. In dismissing the appeal on that basis, the NLRC seemed to prefer form
and technicality to substance and justice. Thereby, the NLRC acted arbitrarily, for its
dismissal of the appeal became entirely inconsistent with the constitutional mandate
for the protection to labor.

CA's overturning of the NLRC's ruling was based on its finding that the petitioners
did not sufficiently establish the just and valid cause to dismiss the respondents from
their employment. As the assailed judgment indicates, the CA's review was thorough
and its ruling judicious. It is the employer who bore the burden to show that the
dismissal was for just and valid cause. The failure of the petitioners to discharge their
burden of proof as the employers necessarily meant that the dismissal was illegal.