6/7/2020
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Ruling of the Court of Appeals
Respondents sought recourse to the CA via a Petition for Certiorari. In a Decision[19]
dated May 16, 2012, the CA granted the Petition for Certiorari, reversed the findings of
both the Labor Arbiter and NLRC and dismissed Iladan's complaint for illegal dismissal.
According to the CA, Iladan was not dismissed but voluntarily resigned as substantially
proven by her resignation letter, the Affidavit of Release, Waiver and Quitclaim and the
Agreement which were both executed before the Philippine Consulate General as well
as her acceptance of P35,000.00 as full settlement of her claims. Iladan's execution
and signing of a settlement and affidavit duly assisted by the Labor Attache and a
Conciliator-Mediator convinced the CA that Iladan voluntarily severed her employment
relation with respondents. Moreover, the CA held that Iladan failed to prove that she
paid any placement fee. Hence, the CA attributed grave abuse of discretion on the part
of the NLRC in ruling that Iladan was coerced into resigning and in holding that
placement fee was paid despite absence of any factual basis.
Iladan filed a motion for reconsideration which was denied in the CA Resolution[20] of
October 4, 2012.
Issues
Hence, this Petition raising the following issues: (1) whether the CA may reverse the
factual findings of both the Labor Arbiter and the NLRC; (2) whether Iladan's
resignation and her execution of the Affidavit of Release, Waiver and Quitclaim and the
Agreement were all voluntarily made; (3) whether Iladan's acceptance of the financial
assistance constitutes final settlement of her claims against respondents; (4) whether
Iladan was illegally dismissed; and (5) whether Iladan paid any placement fee.
Our Ruling
The Petition is without merit. The CA did not err in finding that the NLRC committed
grave abuse of discretion in its decision.
Iladan contends that the CA failed to prove any grave abuse of discretion on the part of
the NLRC and thus had no basis in reversing the NLRC resolutions which affirmed the
Labor Arbiter's Decision. She argues that a writ of certiorari may not be used to
correct, the Labor Arbiter's and NLRC's evaluation of evidence and factual findings. She
avers that the factual findings of the Labor Arbiter and the NLRC are entitled to great
weight and should be accorded respect and finality.
Iladan's arguments are untenable. In a special civil action for certiorari, the CA has
ample authority to receive and review the evidence and make its own factual
determination.[21] Thus, the CA is not precluded from reviewing factual findings and
conclusions of the NLRC when it finds that the NLRC committed grave abuse of
discretion in disregarding evidence material to the controversy.[22] In the present case,
we find that the Labor Arbiter and the NLRC acted with grave abuse of discretion
because their tactual findings were arrived at in disregard of the evidence.
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