Producers Bank of the Philippines v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a strike initiated by the Producers Bank Employees Association on October 1, 1984. The petitioner, Producers Bank of the Philippines, alleged that the strike was illegal due to violence, coercion, intimidation, and destruction of property. The Labor Arbiter initially ruled in favor of the bank, finding the strike illegal and supporting the dismissal of employees involved in violent acts. 2. Procedural History: The Labor Arbiter's decision, which supported the dismissal of employees for their involvement in violent acts during the strike, was modified by the National Labor Relations Commission (NLRC). The NLRC ordered the immediate reinstatement of the employees. Producers Bank of the Philippines then filed a petition for review on certiorari with the Supreme Court. 3. The Petition: The Supreme Court initially dismissed the petition for review on certiorari, finding that it raised essentially factual issues and lacked a showing of substantial evidence to support the claim that the NLRC's findings were unsupported or that the NLRC acted with grave abuse of discretion. The petitioner filed a motion for reconsideration, arguing that the NLRC exceeded its jurisdiction and gravely abused its discretion by modifying the Labor Arbiter's decision, which was allegedly supported by substantial evidence of violence and misapplied the Labor Code provisions mandating dismissal for illegal acts during a strike. The petitioner contended that the coercive picketing contributed to the overall illegal conduct and violence.
Issue(s)
Whether the National Labor Relations Commission acted with grave abuse of discretion when it modified the Decision dated March 12, 1985, of the Labor Arbiter. Whether the NLRC exceeded its jurisdiction and gravely abused its discretion in rendering its assailed decision.
Ruling
The motion for reconsideration is DENIED for lack of merit. The denial is FINAL.
Ratio Decidendi
On the issue of grave abuse of discretion: The Supreme Court reiterated its long-standing principle that the findings of fact of the Department of Labor and the National Labor Relations Commission are entitled to great respect and are binding on the Court, unless such findings and conclusions are not supported by substantial evidence. The Court defined "grave abuse of discretion" as a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction, characterized by arbitrary or despotic action due to passion or personal hostility, or a patent and gross evasion of a positive duty. In this case, the Court found no cogent reason to justify a reconsideration of its previous resolution, implying that the NLRC's decision was supported by substantial evidence and did not constitute grave abuse of discretion. On the issue of exceeding jurisdiction and grave abuse of discretion: The Court's refusal to disturb the NLRC's findings on factual matters, such as the extent of violence or its causal link to the dismissal of employees, underscores the deference given to labor tribunals in evaluating evidence. The petitioner's assertion that the NLRC violated Article 265 (now 264) of the Labor Code was implicitly rejected by the Court's affirmation of the NLRC's modification of the Labor Arbiter's decision, which included reinstatement. This suggests the Court found the NLRC's assessment of the evidence and application of the law to be within its jurisdiction and not attended by grave abuse.
Main Doctrine
The findings of fact of the National Labor Relations Commission are entitled to great respect and are binding on the Supreme Court, unless such findings and conclusions are not supported by substantial evidence or the NLRC acted with grave abuse of discretion.