5/28/2020
E-Library - Information At Your Fingertips: Printer Friendly
I.
THE CA ERRED IN TAKING COGNIZANCE OF THE PETITION DESPITE THE
WELL-ESTABLISHED RULE THAT FACTUAL FINDINGS OF LABOR OFFICIALS
ARE ACCORDED NOT ONLY RESPECT BUT EVEN FINALITY.
II.
WHETHER OR NOT THE CA ERRED IN RULING THAT SUNGA’S INJURY WAS
NOT A RESULT OF AN ACCIDENT.
Sunga primarily argues that factual findings of labor officials who are deemed to have
acquired expertise in matters within their respective jurisdiction are generally accorded
not only respect but even finality and bind even the Supreme Court when supported by
substantial evidence; that there was no reason for the CA to reverse the findings of the
labor tribunals. More importantly, granting that the CA indeed has the power to annul
judgments handed by the labor courts, the CA erred in finding that Sunga is not eligible
for disability benefits under the parties’ CBA since he had incurred injury, by accident,
in the performance of his duties.
The Court’s Ruling
We find the petition meritorious.
The assailed CA decision before us is challenged through a Rule 45[14] petition, a
remedy limited to pure questions of law. In this mode of review, we have to examine
the CA decision from the prism of whether it correctly determined the presence or
absence of grave abuse of discretion in the NLRC decision before it, not necessarily on
the basis of whether the NLRC decision on the merits of the case was strictly correct.
[15]
Grave abuse of discretion, amounting to lack or excess of jurisdiction, has been defined
as the capricious and whimsical exercise of judgment amounting to or equivalent to
lack of jurisdiction. There is grave abuse of discretion when the power is exercised in
an arbitrary or despotic manner by reason of passion or personal hostility, and must be
so patent and so gross as to amount to an evasion of a positive duty or to a virtual
refusal to perform the duty enjoined or to act at all in contemplation of law."[16]
Applying the doctrine in the present case, we fail to see any grave abuse of discretion
on the part of the NLRC which would authorize the appellate court to substitute its own
ruling over that of the NLRC. There was ample evidence to support the findings of the
NLRC. The CA, in a Rule 65[17] petition, is limited to a simple review of whether there
existed grave abuse of discretion; the CA should not concern itself with the
determination of whether the NLRC, after evaluation of the evidence presented before
it, had correctly ruled on the merits of the case. The question of intrinsic merits is an
elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/56877
4/9