5/19/2021
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Thus, petitioners insist that the correlation between Buenaflor's nature of work and the
illness which caused his death should have been proven.
Petitioners also reiterate that since Buenaflor did not die as a result of a work-related
illness and his death did not occur during the term of his employment, his minor
children are not entitled to allowance under the POEA-SEC. They further maintain that
respondents are also not entitled to attorney's fees since they failed to show that
petitioners willfully caused loss or injury to them.
The Ruling of the Court
Procedural Considerations
The NLRC decisions brought before the CA are final and executory in nature[4] and can
only be reversed on a finding of grave abuse of discretion.[5] In reviewing the NLRC
cases brought before it through a Rule 65 Petition, the CA merely corrects errors of
jurisdiction or acts committed without jurisdiction or in excess of jurisdiction, or grave
abuse of discretion amounting to lack or excess of jurisdiction.[6] It does not address
mere errors of judgment, unless such errors overstep the bounds of the NLRC's
jurisdiction.[7]
This Court, in reviewing the present Rule 45 Petition, is bound by the intrinsic
limitations of the Rule 65 proceedings.[8]
In resolving a Rule 45 review of the CA's decision in labor cases rendered under Rule
65 of the Revised Rules of Court, the Court merely looks into the legal errors that the
CA may have committed in determining the presence or the absence of grave abuse of
discretion in the NLRC decision that it reviewed.[9]
The question to ask is: did the CA correctly determine whether the NLRC committed
grave abuse of discretion in ruling on the case?[10]
It also settled that in a Rule 45 review, only questions of law may be raised before the
Court.[11] In Jebsen Maritime, Inc. v. Ravena,[12] however, this Court ruled that "(I)n
situations where insufficient or insubstantial evidence have been adduced to support
the findings under review, or when conclusions go beyond bare and incomplete facts
submitted by the claimant, grave abuse of discretion may result and the Court is
permitted to address factual issues." In such instance, the Court's factual review power
is only to the extent necessary to determine whether the CA correctly found no grave
abuse of discretion on the part of the NLRC in finding that respondents are entitled to
death benefits.[13]
Thus, guided by the foregoing, the Court now proceeds to determine whether or not
the CA erred in ruling that the NLRC did not act with grave abuse of discretion in
finding petitioners liable for death benefits, allowance for minor children of Buenaflor,
and attorney's fees.
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