Saturday, January 12, 2008 Factual findings subject to review By Dominador A. Almirante Labor case digest
IN a case for illegal dismissal and money claims, the labor arbiter declared that the dismissal of petitioner Agripino V. Molina was legal for serious misconduct, fraud or willful breach of trust and confidence. The National Labor Relations Comission (NLRC) disagreed and reversed the labor arbiter’s findings. The Court of Appeals (CA) concurred with the findings of the labor arbiter.
Can the foregoing factual findings be the subject of review by the Supreme Court?
Ruling: Yes.
The labor arbiter and the NLRC act in quasi-judicial capacity in resolving cases after hearing and on appeal, respectively. On the presumption that they have already acquired expertise in their jurisdiction, which is confined on specific matters, their findings of facts are often accorded not only with respect but even with finality, if supported by substantial evidence.
However, in spite of the statutory provision making “final” the decision of the NLRC, the Court has taken cognizance of petitions challenging such decision where there is a clear showing that there is want of jurisdiction, grave abuse of discretion, violation of due process, denial of substantial justice or erroneous interpretation of law. (National Steel Corp. versus Court of Appeals, 436 Phil. 656, 670 [2002]).
In view of the discordance between the findings of the labor arbiter and the CA on one hand and the NLRC on the other, there is a need for the Court to review the factual findings and the conclusions based on the said findings.
(Agripino V. Molina versus Pacific Plans, Inc. G.R. No. 165476, March 10, 2006).
