Hubilla vs. HSY Marketing, Ltd., Co.

850 SCRA 372 , January 10, 2018

FACTS:

The respondents HSY Marketing Ltd., et. al. is engaged in manufacturing and selling goods under the
brand “Novo Jeans”. The employees claimed that they were illegally dismissed. Consequently, the case
was referred to the Department of Labor and Employment (DOLE) for amicable settlement, but no
settlement was reached. Petitioner Charlie Hubilla filed a complaint for illegal dismissal against
respondent HSY Marketing Ltd.

The Labor Arbiter (LA) dismissed the complaint for lack of merit.

The National Labor Relations Commission (NLRC) reversed the LA decision and found that petitioner was
illegally dismissed. The Court of Appeals (CA) reversed the decision of the NLRC and reinstated the LA
decision.

Petitioner contended that the CA cannot review the factual findings of the NLRC. Respondent contended
otherwise.

Issue:

1. Whether or not the doubt should be resolved in favor of labor.

2. Whether or not the Court of Appeals may, in a petition for certiorari, review and re-assess the
factual findings of the National Labor Relations Commission.

Held:

1. Yes. When the evidence in labor cases is in equipoise, doubt is resolved in favor of the
employee. This is in line with the policy of the State to afford greater protection to labor.
Petitioners allege that they were illegally dismissed from service when they were prevented
from entering their work premises a day after airing their grievance in a radio show. On the
other hand, respondents deny this allegation and state that petitioners were never dismissed
from employment. In illegal dismissal cases, the burden of proof is on the employer to prove
that the employee was dismissed for a valid cause and that the employee was afforded due
process prior to the dismissal.

2. Yes. Factual findings of labor officials exercising quasi-judicial functions are accorded great
respect and even finality by the courts when the findings are supported by substantial evidence.

Substantial evidence is “the amount of relevant evidence which a reasonable mind might accept
as adequate to support a conclusion.” Thus, in labor cases, the issues in petitions for certiorari
before the Court of Appeals are limited only to whether the National Labor Relations
Commission committed grave abuse of discretion.

However, this does not mean that the Court of Appeals is conclusively bound by the findings of
the National Labor Relations Commission.
If the findings are arrived at arbitrarily, without resort to any substantial evidence, the National
Labor Relations Commission is deemed to have gravely abused its discretion:

On this matter, the settled rule is that factual findings of labor officials, who are deemed to have
acquired expertise in matters within their jurisdiction, are generally accorded not only respect
but even finality by the courts when supported by substantial evidence, i.e., the amount of
relevant evidence which a reasonable mind might accept as adequate to support a conclusion.

We emphasize, nonetheless, that these findings are not infallible. When there is a showing that
they were arrived at arbitrarily or in disregard of the evidence on record, they may be examined
by the courts.

The Court of Appeals can then grant a petition for certiorari if it finds that the National Labor
Relations Commission], in its assailed decision or resolution, has made a factual finding that is
not supported by substantial evidence. It is within the jurisdiction of the Court of Appeals,
whose jurisdiction over labor cases has been expanded to review the findings of the National
Labor Relations Commission.

Thus, in the determination of whether the National Labor Relations Commission committed
grave abuse of discretion, the Court of Appeals may re-examine facts and re- assess the
evidence. However, its findings may still be subject to review by this Court.

This Court notes that in cases when the Court of Appeals acts as an appellate court, it is still a
trier of facts. Questions of fact may still be raised by the parties. If the parties raise pure
questions of law, they may directly file with this Court.

Moreover, contradictory factual findings between the National Labor Relations Commission and
the Court of Appeals do not automatically justify this Court’s review of the factual findings. They
merely present a prima facie basis to pursue the action before this Court.

The need to review the Court of Appeals’ factual findings must still be pleaded, proved, and
substantiated by the party alleging their inaccuracy. This Court likewise retains its full discretion
to review the factual findings.