G.R. No. 168749 - SUGARSTEEL INDUSTRIAL, INC. AND MR. BEN YAPJOCO, VS. VICTOR ALBINA, VICENTE UY AND ALEX VELASQUEZ.D E C I S I O N - Supreme Court E-Library

Ruling

WHEREFORE , the appeal of complainants is hereby DISMISSED for failure of the appellants to comply with Article 223 of the Labor Code. Consequently, the decision of the Labor Arbiter is AFFRIMED . SO ORDERED . [6] On May 8, 2000, the NLRC denied the respondents, [7] motion for reconsideration, opining thusly: We reiterate Our ruling that complainants' appeal was not filed in the manner prescribed by law, hence should be properly dismissed. Besides, even if We decide the appeal on its merits, We find no cogent reason to depart from the ruling of the Labor Arbiter supported as it is by the evidence on record. [8] Judgment of the CA Aggrieved, the respondents assailed the result through their petition for certiorari in the CA, averring that: THE HONORABLE COMMISSION COMMITTED GRAVE ABUSE OF DISCRETION IN AFFIRMING IN TOTO THE DECISION OF THE LABOR ARBITER DECLARING THE DISMISSAL OF THE PETITIONERS AS VALID ON THE GROUND OF GROSS NEGLIGENCE. In the judgment promulgated on January 9, 2004, [9] the CA granted the petition for certiorari. It ruled that the NLRC's affirmance of the LA's decision did not accord with the evidence on record and the applicable law and jurisprudence; that the dismissal of the respondents' appeal constituted grave abuse of discretion amounting to lack or excess of jurisdiction; [10] and that based on its review the respondents had been illegally dismissed considering that the petitioners did not establish that the respondents were guilty of gross and habitual neglect. Issues In this recourse, the petitioners submit that the CA gravely abused its discretion by disregarding the factual findings of the LA that the NLRC affirmed; that such findings, being supported by substantial evidence, were binding and conclusive on the CA; that the review of the decisions of the NLRC through certiorari was confined to determining issues of want or excess of jurisdiction and grave abuse of discretion amounting to lack or excess of jurisdiction; that certiorari required a clear showing that the respondent court or officer exercising judicial or quasi-judicial functions committed an error of jurisdiction because an error of judgment was not necessarily grave abuse of discretion; and that the CA thus exceeded its jurisdiction in making its own findings after re-assessing the facts and the sufficiency of the evidence presented to the LA. Did the CA depart from well-settled rules on what findings the CA could review on certiorari ? [11] Ruling of the Court The petition for review on certiorari lacks merit. The CA acted in accordance with the pertinent law and jurisprudence. As a rule, the certiorari proceeding, being confined to the correction of acts rendered without jurisdiction, in excess of jurisdiction, or with grave abuse of discretion that amounts to lack or excess of jurisdiction, is limited in scope and narrow in character. As such, the judicial inquiry in a special civil action for certiorari in labor litigation ascertains only whether or