Facts
Private respondent Bienvenido Aricayos filed a complaint for illegal dismissal before the National Labor Relations Commission (NLRC) against petitioner St. Martin Funeral Home, where he claimed to have worked as Operations Manager from February 6, 1995, until his dismissal on January 22, 1996. St. Martin Funeral Home countered that Aricayos was not an employee but only the uncle of the owner, who voluntarily helped oversee the business. The Labor Arbiter declared that no employer-employee relationship existed and dismissed the case for lack of jurisdiction. The private respondent appealed, and the NLRC set aside the Labor Arbiter’s decision, remanding the case for immediate appropriate proceedings. St. Martin Funeral Home filed the present petition for certiorari directly with the Supreme Court, alleging that the NLRC committed grave abuse of discretion. The Supreme Court took this opportunity to reexamine the functional validity of the mode of judicial review concerning decisions of the NLRC.
Issues
- What is the proper and intended mode of judicial review for decisions, resolutions, orders, or awards issued by the National Labor Relations Commission (NLRC)?
- Which court has initial jurisdiction over petitions seeking judicial review of NLRC decisions, and how does this relate to the doctrine on the hierarchy of courts?
Ruling
“Therefore, all references in the amended Section 9 of B.P. No. 129 to supposed appeals from the NLRC to the Supreme Court are interpreted and hereby declared to mean and refer to petitions for certiorari under Rule 65. Consequently, all such petitions should henceforth be initially filed in the Court of Appeals in strict observance of the doctrine on the hierarchy of courts as the appropriate forum for the relief desired”.
“WHEREFORE, under the foregoing premises, the instant petition for certiorari is hereby REMANDED, and all pertinent records thereof ordered to be FORWARDED, to the Court of Appeals for appropriate action and disposition consistent with the views and ruling herein set forth, without pronouncement as to costs. SO ORDERED.”.
Essential Elements of Jurisprudence
- Mode of Review: The established mode of judicial review over decisions, resolutions, orders, or awards of the NLRC is the special civil action of certiorari under Rule 65 of the Rules of Court.
- Statutory Interpretation: Although subsequent legislation (R.A. No. 7902 amending Section 9 of B.P. No. 129) contained ambiguous terminology suggesting “appeals” from the NLRC to the Supreme Court, this was interpreted as a lapsus plumae (slip of the pen). There is no provision in the Labor Code (P.D. No. 442) for actual appellate review (appeal) from the NLRC.
- Jurisdiction and Hierarchy of Courts: Petitions for certiorari assailing the NLRC decisions must be initially filed with the Court of Appeals. This directive requires strict observance of the doctrine on the hierarchy of courts. Direct resort to the Supreme Court will not generally be entertained unless the redress cannot be obtained elsewhere or exceptional circumstances justify primary jurisdiction.
- Rationale: The Court of Appeals is deemed the appropriate forum because it shares concurrent original jurisdiction for the writ of certiorari, is procedurally equipped to try cases, conduct hearings, and resolve factual issues, and placing the initial review there helps to ease the workload of the Supreme Court.
Sample Q&A
Question: Petitioner XYZ Corp. received an unfavorable resolution from the NLRC denying its motion for reconsideration in an illegal dismissal case. XYZ Corp. immediately files a Petition for Review on Certiorari directly with the Supreme Court, arguing that the NLRC decision involved a pure question of law and that Section 9(3) of B.P. No. 129 (as amended by R.A. No. 7902) implies that certain labor cases fall under the appellate jurisdiction of the Supreme Court. Is the action taken by XYZ Corp. procedurally correct? Explain, citing the relevant mode of review and the established judicial policy.
Answer: No, the action taken by XYZ Corp. is procedurally incorrect.
Under the controlling doctrine established by the Supreme Court, there is no appeal provided for decisions of the NLRC under the Labor Code of the Philippines (P.D. No. 442, as amended, particularly Article 223 concerning finality). The judicial review mechanism is solely through the special civil action of certiorari under Rule 65 of the Rules of Court, limited to issues of jurisdiction or grave abuse of discretion.
While R.A. No. 7902 (amending Section 9 of B.P. No. 129) mentioned certain labor cases supposedly falling under the Supreme Court’s “appellate jurisdiction,” the Supreme Court interpreted this language to refer only to certiorari under Rule 65.
Furthermore, although the Supreme Court and the Court of Appeals possess concurrent original jurisdiction over petitions for certiorari, judicial policy dictates that the petition must be initially filed with the Court of Appeals in strict observance of the doctrine on the hierarchy of courts. Direct resort to the Supreme Court is a practice that must be stopped unless compelling and exceptional circumstances are shown. The Supreme Court is not a trier of facts, and the Court of Appeals is better equipped to handle the initial review of factual issues that may arise in labor disputes.
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