3/27/2020 E-Library - Information At Your Fingertips: Printer Friendly words, in testing for legal correctness, the Court views the CA decision in the same context that the petition for certiorari it ruled upon was presented to it. We draw attention at this point to the basic postulate that in the judicial review of labor tribunals’ rulings, their factual findings and the conclusions from these findings are generally accorded respect by the courts because of the tribunals’ expertise in their field. There is also the reality that the ruling brought under Rule 65 to the CA is already a final and executory ruling and can only be disturbed if it is void because the NLRC acted without jurisdiction. This postulate should be related to the intrinsic limitations of a certiorari proceeding: it is a limited remedy aimed solely at the correction of acts rendered without jurisdiction, in excess of jurisdiction, or with grave abuse of discretion; it does not, and cannot, address mere errors of judgment. Of course, the rule that a certiorari proceeding normally precludes an inquiry into the correctness of the labor tribunal’s evaluation of the evidence on which its decision is based, is not absolute; circumstances may exist that would allow the court’s review of the tribunals’ factual findings and the supporting evidence. One instance is when there is a showing that the NLRC’s factual findings and conclusions were arrived at arbitrarily or in disregard of the evidence on record. Another instance is when the tribunal, such as the NLRC in this case, made factual findings that are not supported by substantial evidence. By established jurisprudence, these kinds of rulings are tainted by grave abuse of discretion. In the present case, the labor tribunals agree that Dennis committed suicide by jumping from the ship because of his heavy “personal and psychological problems,”[22] as shown by the unusual behavior he exhibited days before the incident. The CA disagreed with the labor tribunals and ruled that even with Dennis’ unusual behavior, the “willfulness to take his own life could not be presumed when he jumped overboard” and in fact “cast serious doubt” on the petitioners’ claim of willfulness. It added that AB Tamayo’s statements that he saw Dennis jump overboard and thereafter make no effort to reach the life ring “are not conclusive proof” of suicide. As matters stand, the Court needs only to determine whether the CA correctly found that the NLRC gravely abused its discretion in holding that substantial evidence exists to support its conclusion that Dennis willfully took his own life. b. Burden of proof in death benefits cases; burden of evidence In determining whether there was substantial evidence to support the NLRC’s finding that Dennis committed suicide, we find it necessary to discuss the burden of proof and the corresponding shift in the burden of evidence in death benefits cases under the POEA-SEC. The relevant provision of the POEA-SEC pertinently reads: D. No compensation shall be payable in respect of any injury, incapacity, disability or death of the seafarer resulting from his willful or criminal elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/57997 4/13