Department of Health v. Nestle Philippines
REITERATIONFacts
The Antecedents: On October 16, 2007, Mymanette M. Jarra purchased a 150-gram pack of Nestle Bear Brand Powdered Filled Milk. Upon opening, she discovered objects resembling larvae and a yellowish, lumpy powder, rendering it unfit for consumption. Jarra filed a complaint with the Department of Health (DOH) Consumer Arbitration Office (CAO-NCR). Procedural History: The Bureau of Food and Drugs (BFAD) Report of Analysis No. FCM07-10-18-151 dated October 22, 2007, confirmed the presence of live insect larvae and a stale odor, deeming the product unfit for human consumption. The CAO-NCR, finding a violation of Republic Act No. 7394 (Consumer Act of the Philippines), ordered Nestle to pay a fine, provide assurance of compliance, restitute the complainant, pay expenses, and condemn the product. Nestle's motion for reconsideration was denied. The Secretary of Health affirmed the CAO-NCR's decision with modification, deleting the award for expenses. Nestle's subsequent motion for reconsideration was denied. Nestle then filed a Petition for Certiorari before the Court of Appeals (CA), alleging grave abuse of discretion by the DOH. The Petition: The CA reversed the DOH's decision, finding the BFAD report ambiguous and concluding that the infestation could have occurred due to factors other than Nestle's defective handling. The DOH, through a Petition for Review on Certiorari, assailed the CA's decision, arguing that it committed grave abuse of discretion by relying on errors of judgment instead of errors of jurisdiction and by disregarding substantial evidence.
Issue(s)
Whether the Court of Appeals committed grave abuse of discretion amounting to lack or excess of jurisdiction in reversing the decision of the Department of Health. Whether the Department of Health committed grave abuse of discretion in affirming the decision of the Consumer Arbitration Office finding Nestle Philippines, Inc. liable for violation of Republic Act No. 7394.
Ruling
The Supreme Court granted the Petition for Review on Certiorari, reversed the Court of Appeals' Decision and Resolution, and reinstated the Department of Health's Decision and Resolution with modification. The Court ordered Nestle Philippines, Inc. to pay an administrative fine of P20,000.00, provide assurance of compliance with RA 7394, restitute the complainant with one (1) Bear Brand Powdered Filled Milk (150g pack) or its value, and the condemnation of the subject product.
Ratio Decidendi
On the issue of whether the Court of Appeals committed grave abuse of discretion: The Court held that a petition for certiorari under Rule 65 is strictly limited to correcting errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction. The Court emphasized that the CA's supervisory jurisdiction over a writ of certiorari cannot be used to review the intrinsic correctness of a lower court's or quasi-judicial body's judgment, whether on law or facts, or the wisdom of its decision. The CA's decision was found to have evaluated the evidence on record and dwelt on errors in judgment committed by the DOH, rather than errors of jurisdiction, which is not the proper basis for a writ of certiorari. The CA failed to make clear and distinct findings as to the presence of grave abuse of discretion on the part of the DOH. Therefore, the CA committed grave abuse of discretion in reversing the DOH's decision. On the issue of whether the Department of Health committed grave abuse of discretion: The Court found that the DOH did not commit grave abuse of discretion. The DOH's decision was based on substantial evidence, namely, the complaint filed by Jarra and the BFAD Report of Analysis, which confirmed that the milk product contained live larvae and was unfit for human consumption. The Court reiterated the doctrine of conclusiveness of administrative findings of fact, which states that courts accord great weight and respect to such findings when supported by substantial evidence, as administrative bodies are presumed to possess expertise in their respective fields. Nestle failed to present sufficient evidence to overcome the findings of the BFAD and the DOH, relying only on denials and suppositions that the infestation could have been caused by other factors. The DOH correctly gave more credence to the BFAD's findings and prioritized consumer welfare. Thus, the DOH's decision was within the bounds of law and supported by substantial evidence, and no grave abuse of discretion could be attributed to it.
Main Doctrine
The findings of administrative bodies, when supported by substantial evidence, are accorded great weight and respect. A petition for certiorari under Rule 65 is limited to correcting errors of jurisdiction or grave abuse of discretion, not errors of judgment or the correctness of factual findings.