G.R. No. 194575 - ANGELITO N. GABRIEL, VS. PETRON CORPORATION, ALFRED A. TRIO, AND FERDINANDO ENRIQUEZ.DECISION - Supreme Court E-Library

Ruling

WHEREFORE, petitioner's motion for extension is denied and accordingly, the present case is dismissed. [24] From this, Gabriel filed his motion for reconsideration with prayer to admit the attached petition for certiorari claiming that the factual circumstances of his case are exceptional and merit a relaxation of the rules of procedure. [25] After considering the submissions of both parties, the CA maintained that Gabriel's motion failed to present any substantial and meritorious ground which would justify a reversal of its earlier ruling. [26] OUR RULING Aggrieved, Gabriel now seeks relief before this Court through this present petition. At the onset, Gabriel wants to correct the serious error the CA committed in denying his motion for extension out of sheer technicality. At the same time, Gabriel imputes grave abuse of discretion amounting to lack or in excess of jurisdiction on the part of the NLRC for setting aside the findings of constructive dismissal and reversing the decision of the labor arbiter. Under our present labor laws, there is no provision for appeals from the decision of the NLRC. In fact, under Article 229 of the Labor Code, all decisions of the NLRC shall be final and executory after ten (10) calendar days from receipt thereof by the parties. Nevertheless, appellate courts - including this Court - still have an underlying power to scrutinize decisions of the NLRC on questions of law even though the law gives no explicit right to appeal. Simply said, even if there is no direct appeal from the NLRC decision, the aggrieved party still has a legal remedy. Certiorari proceedings are limited in scope and narrow in character because they only correct acts rendered without jurisdiction, in excess of jurisdiction, or with grave abuse of discretion. Indeed, relief in a special civil action for certiorari is available only when the following essential requisites concur: (a) the petition must be directed against a tribunal, board, or officer exercising judicial or quasi-judicial functions; (b) the tribunal, board, or officer must have acted without or in excess of jurisdiction or with grave abuse of discretion amounting to lack or in excess of jurisdiction; and (c) there is no appeal, nor any plain, speedy, and adequate remedy in the ordinary course of law. [27] It will issue to correct errors of jurisdiction and not mere errors of judgment, particularly in the findings or conclusions of the quasi-judicial tribunals (such as the NLRC). Accordingly, when a petition for certiorari is filed, the judicial inquiry should be limited to the issue of whether the NLRC acted with grave abuse of discretion amounting to lack or in excess of jurisdiction. [28] In St. Martin Funeral Home v. NLRC , [29] the Court laid down the proper recourse should the aggrieved party seek judicial review of the NLRC decision: The Court is, therefore, of the considered opinion that ever since appeals from the NLRC to the Supreme Court were eliminated, the legislative