Bugaoisan v. OWI Group Manila, Inc.
REITERATIONFacts
The Antecedents: Petitioner Agnes Coeli Bugaoisan responded to an advertisement for a chef position in Australia offered by OWI Group Manila, Inc. (OWI), agent of Morris Corporation (Morris). She was offered a full-time position with a salary of AUS$60,000 per annum and a one-year employment contract. Upon arrival in Perth, Australia, she was offered a new position as breakfast chef with a salary of AUS$75,000 per annum. She was deployed to a mining site where she was tasked to prepare breakfast for a large number of employees by herself, leading to overwhelming duties. She was later transferred to another site with more employees. While preparing breakfast, she experienced tingling and numbness in her hands, diagnosed as Carpal Tunnel Syndrome (CTS), and was advised surgery. Her compensation claim for wages while unfit for work and medical expenses was denied. Morris informed her that her paid leaves were exhausted and she would only be allowed to return to work once declared fit. Due to financial difficulties, she resigned and returned to the Philippines. She subsequently filed a labor complaint for constructive illegal dismissal, unpaid salaries, overtime pay, and medical expenses. Procedural History: The Labor Arbiter (LA) ruled that petitioner was illegally dismissed, finding gross misrepresentation and bad faith by respondents, and ordered payment of salaries for the unexpired portion of a two-year contract, moral and exemplary damages, and attorney's fees. The National Labor Relations Commission (NLRC) affirmed the LA's findings on constructive dismissal, solidary liability, and the award of salaries for the unexpired portion of a two-year contract. Respondents filed a petition for certiorari with the Court of Appeals (CA). The CA affirmed the NLRC's finding of no grave abuse of discretion but modified the award of unpaid salaries, reducing it to AUS$56,250 based on a one-year contract duration. Petitioner moved for partial reconsideration, which was denied by the CA. The Petition: Petitioner filed a petition for review on certiorari under Rule 45, seeking to annul the CA's decision and resolution, arguing that the CA erred in ruling that her employment contract was for only one year and in modifying the award of unpaid salaries.
Issue(s)
Whether the Court of Appeals gravely erred when it ruled that petitioner's employment contract with Morris was for only one (1) year as per its POEA Master Employment Contract, and whether the CA exceeded its certiorari jurisdiction in modifying the NLRC's decision. Whether the contract was validly modified by Morris' subsequent "Offer of Fulltime Employment" for at least two (2) years, thus entitling her to the unpaid salaries for the unexpired portion of the two-year contract, considering the scope of certiorari review and the finality of factual findings.
Ruling
The petition is GRANTED. The Decision dated February 24, 2016 and Resolution dated August 3, 2016 of the Court of Appeals in CA-G.R. SP No. 131670 are AFFIRMED with MODIFICATION. The Decision dated May 31, 2013 of the National Labor Relations Commission with respect to the award of unpaid salaries to petitioner Agnes Coeli Bugaoisan for the unexpired portion of her two-year contract with respondents OWI Group Manila, Inc. and Morris Corporation is REINSTATED.
Ratio Decidendi
On the issue of the contract duration and the CA's modification of the award: The Court reiterated that a petition for review on certiorari under Rule 45 is limited to questions of law, while a petition for certiorari under Rule 65, as filed with the CA, is confined to the determination of whether the lower tribunal acted without, in excess of, or with grave abuse of discretion. The CA, in reviewing the NLRC's decision via Rule 65, should have limited itself to the jurisdictional errors or grave abuse of discretion imputed to the NLRC. The CA erred when it modified the award of unpaid salaries by reducing it to an amount based on a one-year contract duration, despite this issue not being raised by the respondents in their petition for certiorari before the CA. The CA's modification of the factual finding regarding the contract duration went beyond the scope of its certiorari jurisdiction. On the validity of the contract modification and entitlement to unpaid salaries: A writ of certiorari under Rule 65 cannot be used to correct errors of judgment or review the intrinsic correctness of a lower court's decision on the basis of law or facts, unless there is grave abuse of discretion amounting to lack or excess of jurisdiction. The CA's supervisory jurisdiction under Rule 65 is limited to keeping the inferior court within the bounds of its jurisdiction. It cannot substitute its own judgment for that of the NLRC on factual matters, especially when such matters were not assigned as errors or raised in the pleadings before it. Factual findings of the Labor Arbiter, as affirmed by the NLRC, are generally considered conclusive and binding on the Supreme Court, absent any showing that the NLRC acted without, in excess of, or with grave abuse of discretion. In this case, the CA found no grave abuse of discretion on the part of the NLRC. Therefore, the CA should not have disturbed the NLRC's factual finding regarding the two-year duration of the employment contract and the corresponding award of unpaid salaries. Since the CA erred in modifying the award of unpaid salaries based on a one-year contract duration, and given that the NLRC's factual findings were affirmed as not being tainted with grave abuse of discretion, the Supreme Court reinstated the NLRC's decision which awarded unpaid salaries based on a two-year employment contract. The CA departed from the issues presented by the parties and decided by the labor tribunals when it modified the award of unpaid salaries. The CA's basis for modification, which was the perceived lack of clarity on the contract extension and the application of contract perfection rules, constituted a review of the merits of the case, which is not the office of a Rule 65 certiorari petition. The CA's action was an error of judgment, not an error of jurisdiction.
Main Doctrine
The Court of Appeals, in a petition for certiorari under Rule 65, is confined to determining whether the NLRC committed grave abuse of discretion. It cannot modify factual findings of labor tribunals, especially on matters not raised as errors in the petition, as this would go beyond the scope of certiorari and encroach upon questions of fact, which are outside its jurisdiction in such a proceeding.