Labor case; Certiorari under Rule 65 and appeal under Rule 45

G.R. No. 191034               October 1, 2014

AGILE MARITIME RESOURCES INC., ATTY. IMELDA LIM BARCELONA and PRONA V SHIP MANAGEMENT, INC., Petitioners,
vs.
APOLINARIO N. SIADOR, Respondent.

"x x x.
In a Rule 45 review of a CA ruling rendered pursuant to Rule 65, the Court determines the legal correctness of the CA decision based on its determination of the presence or absence of grave abuse of discretion in the NLRC decision that the CA reviewed, not on the basis of whether the NLRC decision on the merits of the case was correct. In other 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 certiorariproceeding: 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 certiorariproceeding 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.

X x x."