Pfizer v. Galan
REITERATIONFacts
The Antecedents: Petitioner Pfizer, Inc., a pharmaceutical company, employed respondent Edwin V. Galan as a medical representative in August 1982. Galan received several promotions and awards for exceeding sales targets, eventually becoming District Manager for Mindanao. In September 1997, Pfizer issued a memorandum requiring Galan to explain his alleged unauthorized use of a company vehicle, questionable expense claims, and doubtful liquidation of a cash advance. Following an investigation and preventive suspension, Galan was terminated on October 31, 1997, by petitioner Maria Angelica B. Lleander, Pfizer's Human Resource Director, on the grounds of loss of trust and confidence. Procedural History: Respondent Galan filed a complaint for illegal dismissal against Pfizer, Inc. and Lleander with the Regional Arbitration Branch No. 9, Zamboanga City. The Labor Arbiter ruled in favor of Galan, finding him illegally dismissed and awarding him P2,052,013.50 in backwages, 13th month pay, incentives, expenses, and attorney's fees. The National Labor Relations Commission (NLRC) affirmed this decision on appeal, and a subsequent motion for reconsideration was denied. The NLRC decision became final and executory on July 5, 1999. Subsequently, Pfizer and Lleander filed a petition for certiorari with the Court of Appeals, which dismissed their petition for being filed beyond the reglementary period. This dismissal was affirmed upon denial of their motion for reconsideration. The Supreme Court, in a prior G.R. No. 143389, set aside the Court of Appeals' dismissal and remanded the case for further proceedings. On January 16, 2003, the Court of Appeals rendered a new decision, denying the petition and affirming the NLRC's resolutions. The Petition: Petitioners Pfizer, Inc. and Maria Angelica B. Lleander are seeking review on certiorari of the January 16, 2003 Decision of the Court of Appeals, which denied their petition for certiorari and affirmed the NLRC's resolutions finding respondent Edwin V. Galan's dismissal to be illegal. The petitioners argue that the Court of Appeals erred in dismissing their action for certiorari. The Supreme Court, in its resolution, addresses the fundamental issue of whether the Court of Appeals erred in dismissing the petitioners' action for certiorari, reiterating established jurisprudence that factual issues are generally beyond the scope of certiorari and that factual findings of the NLRC, affirmed by the Court of Appeals, are binding upon the Supreme Court unless there is grave abuse of discretion or lack of jurisdiction.
Issue(s)
Whether the Court of Appeals erred in dismissing petitioners’ action for certiorari. Whether the dismissal of respondent for loss of trust and confidence was justified.
Ruling
The petition is denied. The assailed Decision of the Court of Appeals is affirmed in toto.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in dismissing petitioners’ action for certiorari: The Supreme Court reiterated that in labor cases, the appellate court's jurisdiction to review an NLRC decision via certiorari is limited to issues of jurisdiction or grave abuse of discretion. The extraordinary writ of certiorari is solely for correcting errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction. Factual issues are generally beyond the scope of certiorari as they do not involve jurisdictional questions. The Court emphasized two jurisprudential rules: first, factual issues are beyond the scope of certiorari; and second, factual findings of the NLRC affirming those of the Labor Arbiter, if devoid of unfairness or arbitrariness, are accorded respect, even finality, by the Court of Appeals. When these findings are affirmed by the CA, they become binding and conclusive upon the Supreme Court. The Supreme Court clarified that it is not its function to inquire into the correctness of the evaluation of evidence by labor officials, especially when their findings have been affirmed by the Court of Appeals. On the issue of whether the dismissal of respondent for loss of trust and confidence was justified: The Supreme Court sustained the factual findings of the labor agencies and the Court of Appeals. These findings indicated that there was no deliberate attempt on the respondent's part to defraud his employer. Consequently, his dismissal from the service was deemed unjustified. The Court reiterated that it would not disturb the findings of facts of officials who have gained expertise in their specialized field, particularly when such findings have been given the stamp of approval by the Court of Appeals. Therefore, the dismissal based on loss of trust and confidence was not supported by substantial evidence as determined by the labor tribunals and affirmed by the appellate court.
Main Doctrine
Factual findings of the NLRC affirming those of the Labor Arbiter, when devoid of unfairness or arbitrariness, are accorded respect by the Court of Appeals, and where affirmed by the Court of Appeals, are deemed binding and conclusive upon the Supreme Court. The extraordinary writ of certiorari under Rule 65 is confined to issues of jurisdiction or grave abuse of discretion, not errors of fact.