Philippine Plywood Corporation v. National Labor Union
REITERATIONFacts
1. The Antecedents: In August 1950, thirty-seven employees of the Philippine Plywood Corporation were dismissed. The underlying dispute centers on whether these dismissals were for just cause, as the Corporation contended, or without just cause, as the employees alleged. The Corporation maintained that some employees were given one month's separation pay in lieu of notice, while others were dismissed for just cause. 2. Procedural History: The dismissed employees sought inclusion in Case No. 462-V of the Court of Industrial Relations, which was subsequently retitled Case No. 553-V. On October 22, 1958, the Court of Industrial Relations rendered a judgment finding that most of the employees had been dismissed without just cause and ordered their reinstatement with varying backpay. This decision was affirmed by the Court sitting en banc upon a motion for reconsideration. The Corporation filed a notice of appeal on March 11, 1959, forty days after the resolution denying the motion for reconsideration, which was promulgated on January 30, 1959. 3. The Petition: The Philippine Plywood Corporation filed a petition with the Supreme Court, styled as a special civil action for certiorari, but also suggesting it could be treated as an appeal by certiorari. The petition argued that the Court of Industrial Relations gravely abused its discretion in finding the dismissals unjustified, ordering reinstatement, and awarding backpay. The Corporation sought to have the decision nullified and instead have it declared that the dismissals were justified, reinstatement and backpay denied, and that the payments made were in lieu of notice. However, the Supreme Court noted that the petition was filed over two months after the ten-day period for appeal by certiorari had expired, thus it could only be considered as a special civil action for certiorari, which was found to be without merit.
Issue(s)
Whether the Supreme Court can treat the petition as an appeal by certiorari given its untimeliness. Whether the Court of Industrial Relations committed grave abuse of discretion in finding that most of the employees were dismissed without just cause and in ordering their reinstatement and backpay.
Ruling
The petition for certiorari was dismissed, and the writ prayed for was denied. The Supreme Court held that the petition could not be considered an appeal by certiorari due to its untimeliness and found no grave abuse of discretion on the part of the Court of Industrial Relations.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the petition could not be treated as an appeal by certiorari because it was filed beyond the ten (10)-day reglementary period prescribed by Commonwealth Act No. 103, Section 14. The resolution denying the motion for reconsideration was promulgated on January 30, 1959, and the notice of appeal was filed on March 11, 1959, which is forty (40) days later. The present petition for certiorari was filed on April 16, 1959, over two (2) months after the expiration of the appeal period. Therefore, the case could only be considered as a special civil action of certiorari. On Issue 2: The Supreme Court found no grave abuse of discretion on the part of the Court of Industrial Relations. The Court noted that the CIR had jurisdiction over the case and the parties, and its task was to ascertain the true cause of dismissal and determine its justness. After reviewing the evidence, the CIR concluded that most employees were dismissed without just cause, particularly because the dismissals occurred shortly after an administrative complaint was filed against the Corporation's General Manager. The Court found the CIR's conclusion that the evidence for the employees was more reliable than that of the Corporation to be a matter of judgment, not grave abuse of discretion. The Court also found the evidence of record justified the CIR's conclusions, citing the lack of explanation from the Corporation for the mass dismissals and the timing of these dismissals relative to the charges against the General Manager. The Court also noted that the one-month pay given to some employees was an advance salary, not separation pay.
Main Doctrine
The Supreme Court affirmed that a special civil action for certiorari is not a proper remedy when a timely appeal by certiorari was available but was not availed of within the reglementary period. The Court emphasized that certiorari lies only to correct errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction, and not merely errors of judgment. Furthermore, the Court reiterated that it would not disturb the factual findings of the Court of Industrial Relations, particularly concerning the justness of dismissals, when such findings are supported by substantial evidence, as the appellate court's role is not to re-evaluate evidence already passed upon by the lower tribunal.