Pure Foods Corporation v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondents Remigio Clavio, Andres Catubay, Virgilio Umali, Orlando Rey, and Jorge del Rosario were employees of petitioner Pure Foods Corporation. They were indefinitely suspended on March 18, 1981, immediately after an incident involving alleged pilferage, without prior investigation. Subsequently, they were dismissed without notice or clearance from the Ministry of Labor and Employment. Procedural History: Private respondents filed a complaint for illegal dismissal and unpaid wages. An order from Director Severo M. Pucan directed petitioner to reinstate them with full backwages. Petitioner appealed, and Deputy Minister Vicente Leogardo, Jr. indorsed the complaint to the NLRC-NCR Arbitration Branch for compulsory arbitration. Labor Arbiter Raymundo R. Valenzuela rendered a decision on May 16, 1986, finding the dismissal of Clavio unjustified and ordering his reinstatement with 1.5 years of backwages, while ordering separation pay for the other complainants for failure to furnish clearance. Both parties appealed to the NLRC. On March 23, 1987, the NLRC modified the labor arbiter's decision, ordering the reinstatement of Virgilio Umali, Jorge del Rosario, Orlando Rey, and Andres Catubay to their former positions without loss of seniority rights and payment of three years' backwages each. The NLRC's resolution of May 20, 1987, denied petitioner's motion for reconsideration. The Petition: Petitioner filed a special civil action for certiorari, seeking the annulment of the NLRC's decision and resolution, contending that the NLRC committed grave abuse of discretion in reversing the labor arbiter's findings of fact. Respondents argued that the NLRC decision had become final and executory due to petitioner's failure to file a timely motion for reconsideration.
Issue(s)
Whether the NLRC committed grave abuse of discretion in reversing the findings of fact of the labor arbiter. Whether the NLRC decision had become final and executory due to petitioner's failure to file a timely motion for reconsideration.
Ruling
The petition for certiorari is dismissed. The decision of the Labor Arbiter dated May 16, 1986, insofar as it orders the reinstatement of private respondent Remigio Clavio and the payment of his backwages of one and a half years, is affirmed. The decision of the National Labor Relations Commission dated March 23, 1987, and its resolution of May 20, 1987, are likewise affirmed. If reinstatement is impossible, petitioner is ordered to pay separation pay equivalent to one month's salary for every year of service.
Ratio Decidendi
On the issue of whether the NLRC committed grave abuse of discretion: The Court held that a special civil action for certiorari is a remedy for errors of jurisdiction, not errors of judgment. Grave abuse of discretion implies a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction, which must be shown to be exercised arbitrarily or despotically. The petitioner failed to demonstrate that the NLRC acted whimsically or in total disregard of evidence. The Court emphasized that certiorari cannot be used to circumvent the right of the NLRC to review its own decisions or to shield a party from the consequences of its own negligence. The alleged variances in factual findings do not constitute grave abuse of discretion warranting certiorari. On the issue of whether the NLRC decision had become final and executory: The Court found merit in the respondents' contention that the NLRC decision had become final and executory. Under the New Rules of the National Labor Relations Commission, a motion for reconsideration must be filed within ten (10) calendar days from receipt of the order, resolution, or decision. Petitioner filed its motion for reconsideration beyond this reglementary period, leading to its denial by the NLRC. The Court reiterated that certiorari will lie only if there is no other plain, speedy, and adequate remedy. The failure to timely file a motion for reconsideration, which was the proper remedy, barred petitioner from seeking recourse through certiorari. This procedural flaw was deemed fatal to the petition, as it placed a premium on negligence and prevented the NLRC from correcting any potential errors in its decision.
Main Doctrine
A special civil action for certiorari will not lie if there is a plain, speedy, and adequate remedy in the ordinary course of law, such as a motion for reconsideration, which was not timely availed of due to negligence or indifference. Certiorari is a remedy for errors of jurisdiction, not errors of judgment.