Busmente Jr. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Jose G. Busmente, Jr. filed a complaint against Apolonio Centron (Centronet Enterprises) for illegal dismissal, underpayment, overtime pay, legal holiday pay, and violation of several Presidential Decrees. Busmente described himself as a driver for Centron, which employed approximately 18 workers. Procedural History: The Labor Arbiter initially dismissed the complaint for failure to file a position paper and affidavit, and for failure to appear. Upon motion for reconsideration, the Arbiter required parties to submit position papers and evidence. In a separate case (NLRC-NCR-7-2510-84), Centron had filed against Busmente for damages due to abandonment, a decision was rendered on September 28, 1984, declaring Busmente had lost his employment status due to abandonment. The Arbiter, in the original complaint, found that Busmente's monetary claims could not prosper as Centron had substantiated payment of all required allowances and pays until Busmente's abandonment. The Arbiter also relied on the previous decision finding Busmente had abandoned his work and refused to return despite offers. Busmente's complaint was dismissed. Both decisions were appealed to the National Labor Relations Commission (NLRC), which affirmed the Arbiter's findings. Busmente's appeal in the illegal dismissal case was dismissed on October 25, 1985, finding the Arbiter's conclusions substantially supported by evidence. His appeal in the abandonment case was dismissed on August 8, 1986, holding that Busmente was not denied due process and that abandonment was proven by established facts. The Petition: Busmente filed a petition for certiorari with the Supreme Court, seeking to invalidate the NLRC's August 8, 1986 judgment, primarily challenging the conclusion that the evidence proved his abandonment of work.
Issue(s)
Whether the Supreme Court, in a petition for certiorari under Rule 65, can review questions of fact, specifically the finding of abandonment of work. Whether the respondent Commission committed grave abuse of discretion in affirming the Labor Arbiters' findings of abandonment of work.
Ruling
The petition is DISMISSED. The Supreme Court held that questions of fact are not generally permitted in certiorari proceedings under Rule 65, which is limited to reviewing jurisdictional errors or grave abuse of discretion. The Court found that the Labor Arbiters and the NLRC had jurisdiction, afforded due process, considered evidence, and rendered judgments that, while perhaps debatable or possibly erroneous, could not be characterized as made with grave abuse of discretion.
Ratio Decidendi
On the issue of reviewing questions of fact in a certiorari petition: The Supreme Court reiterated that a petition for certiorari under Rule 65 of the Rules of Court is confined to the determination of whether the respondent tribunal acted without or in excess of its jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction. It is not a remedy for correcting errors of judgment, particularly factual findings, unless such findings were arrived at with grave abuse of discretion. The Court emphasized that the inquiry is limited to the question of jurisdiction and grave abuse of discretion, not errors of law or fact. The Court noted that the resolution of whether Busmente abandoned his work would entail a review of evidence, which is a question of fact. However, given the procedural limitations of a certiorari petition, and finding no grave abuse of discretion, the Court deferred to the factual findings of the NLRC. These findings were based on evidence presented, including a prior decision in a related case that established Busmente's abandonment and refusal to return to work despite offers. The Court found that the Arbiters and the Commission had substantially supported their conclusions with the evidence on record. On whether the NLRC committed grave abuse of discretion: The Court found that the Labor Arbiters and the respondent Commission clearly had jurisdiction over the cases and did not exceed it in hearing and determining the actions. The parties were afforded due process, evidence was presented and considered, and arguments were assessed before judgments were rendered. The factual conclusions reached by the NLRC, including the finding of abandonment, were not considered outrageously wrong, manifestly mistaken, or whimsically or capriciously arrived at. While they might be debatable or possibly erroneous, they did not rise to the level of grave abuse of discretion, which requires a capricious and whimsical exercise of judgment.
Main Doctrine
A petition for certiorari under Rule 65 of the Rules of Court is generally limited to reviewing whether the respondent tribunal acted without or in excess of jurisdiction, or with grave abuse of discretion, and does not ordinarily permit a review of questions of fact. Factual findings of labor arbiters and the NLRC, when supported by substantial evidence, are generally accorded respect and even finality.