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provide. Following these provisions, the amount of P1,928,841.27 that they spent for
Alberto’s medical treatment should, therefore, not be deducted from the disability
benefits to which Alberto was equally entitled. The petitioners, thus, argue that the CA
misconstrued these POEA-SEC provisions (on medical expenses, sickness allowance and
disability benefits) when it affirmed the NLRC’s decision which ordered the deduction of
Alberto’s medical expenses from the total monetary award.
Lastly, the petitioners argue that the respondents failed to prove that they (the
respondents) paid Alberto the amount of P144,318.03 representing his sickness
allowance. They point out that: (1) the respondents belatedly presented the April 12,
2004 certification, the execution of which is even highly questionable; and (2) the
respondents failed to prove via vouchers and/or receipts their payment of the sickness
allowance.
The Case for the Respondents
The respondents maintain[22] that the CA did not err in affirming the NLRC’s resolution
because the NLRC committed no grave abuse of discretion. Relying on the CA’s ruling,
they point out that: (1) the portion of the LA’s decision that denied Alberto’s claim for
reimbursement of medical expenses had already become final and executory, and
therefore unassailable, as Alberto no longer appealed from this decision; and (2) they
had already paid the full amount of Alberto’s sickness allowance.
The Court’s Ruling
We find merit in the petition.
Preliminary considerations:
jurisdictional limitations of the Court’s
Rule 45 review of the CA’s Rule 65
decision in labor cases
In a Rule 45 petition for review on certiorari, what we review are the legal errors that
the CA may have committed in the assailed decision, in contrast with the review for
jurisdictional errors that we undertake in an original certiorari action. In reviewing the
legal correctness of the CA decision in a labor case taken under Rule 65 of the Rules of
Court, we examine the CA decision in the context that it determined the presence or
the absence of grave abuse of discretion in the NLRC decision before it and not on the
basis of whether the NLRC decision, on the merits of the case, was correct.
Otherwise stated, we proceed from the premise that the CA undertook a Rule 65
review, not a review on appeal, of the NLRC decision challenged before it. Within this
narrow scope of our Rule 45 review, the question that we ask is: Did the CA correctly
determine whether the NLRC committed grave abuse of discretion in ruling on the
case?[23]
In addition, the Court’s jurisdiction in a Rule 45 petition for review on certiorari is
limited to resolving only questions of law.
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