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JurisprudenceG.R. No. 235315 -

G.R. No. 235315 -

Cited Laws

RA 468,
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TL;DR — Ruling

The petition is meritorious.

Decision

Ruling

Accordingly, Ventura's employment was automatically terminated upon the happening of the day certain stipulated in the contract. GMA further maintains that it may not be obliged to re-engage Ventura. [37] Ultimately, GMA argues that petitioners could not have been illegally dismissed since they were not regular employees with tenurial security. [38] GMA maintains that as pinch-hitters/freelancers, petitioners' engagement ceased at the end of every shoot. Consequently, there exists no obligation on the part of GMA to re-engage them. [39] For this Court's resolution are the following issues: First, whether or not an employer-employee relationship existed between the petitioners and GMA; Secondassuming the existence of an employer-employee relationshipwhether or not the petitioners are regular employees of GMA; Third, assuming regular employment status, whether or not the petitioners were illegally dismissed. The petition is meritorious. I Labor cases are elevated to this Court through Rule 45 petitions, following Rule 65 petitions decided by the Court of Appeals on rulings made by the National Labor Relations Commission. From this, two (2) chief considerations become apparent: (1) the general injunction that Rule 45 petitions are limited to questions of law; and (2) that the more basic underlying issue is the National Labor Relations Commission's potential grave abuse of its discretion. In labor disputes then, this Court may only resolve the matter of whether the Court of Appeals erred in determining "the presence or absence of grave abuse of discretion and deciding other jurisdictional errors of the National Labor Relations Commission." [40] The general limitation on Rule 45 petitions being concerned with questions of law was discussed in Abuda v. L. Natividad Poultry Farms : [41] When a decision of the Court of Appeals decided under Rule 65 is brought to this Court through a petition for review under Rule 45, the general rule is that this Court may only pass upon questions of law. Meralco Industrial Engineering Services Corp. v. National Labor Relations Commission emphasized as follows: This Court is not a trier of facts. Well-settled is the rule that the jurisdiction of this Court in a petition for review on certiorari under Rule 45 of the Revised Rules of Court is limited to reviewing only errors of law, not of fact, unless the factual findings complained of are completely devoid of support from the evidence on record, or the assailed judgment is based on a gross misapprehension of facts. Besides, factual findings of quasi-judicial agencies like the [National Labor Relations Commission], when affirmed by the Court of Appeals, are conclusive upon the parties and binding on this Court. [42] (Citations omitted, emphasis in the original) In addition, E. Ganzon, Inc. v. Ando, Jr ., [43] citing Montoya v. Transmed , [44] is instructive: In labor cases. Our power of review is limited to the determination of whether the [Court of Appeals] correctly r