Cited Laws
TL;DR — Ruling
The petition is meritorious.
Accordingly, it ordered the Company to reinstate respondents to their former positions without loss of seniority rights and other privileges, with full backwages, and to pay wage and benefits differentials, as well as attorney's fees. [14] Dissatisfied, the Company filed an appeal [15] before the NLRC. The NLRC's Ruling In a Decision [16] dated December 14, 2015, the NLRC reversed the LA's ruling. [17] It held that the redundancy program was done in good faith and was aimed at achieving a more cost-effective operating framework. Thus, it upheld the Company's management decision to abolish the PAG, as well as the validity of the resulting dismissals from employment. [18] Respondents moved for reconsideration [19] but the motion was denied in a Resolution [20] dated January 29, 2016. Hence, they filed a petition for certiorari [21] before the Court of Appeals (CA). The CA's Ruling In a Decision [22] dated December 12, 2016, the CA reversed the NLRC's ruling and reinstated the LA's Decision. [23] The CA explained that while the Company substantiated its need to streamline its operations, it failed to provide fair and reasonable criteria in ascertaining which positions to abolish. Thus, the Company failed to support its allegations of redundancy. Furthermore, the CA refused to uphold the validity of respondents' quitclaims, noting that respondents and the Company did not stand on the same footing. [24] The Company filed a motion for reconsideration, [25] which was, however, denied in a Resolution [26] dated June 30, 2017; hence, this petition. The Issue Before the Court The issue before the Court is whether or not the CA correctly reversed the NLRC's ruling upholding the validity of the redundancy program. The Court's Ruling The petition is meritorious. Preliminarily, the Court stresses the distinct approach in reviewing a CA's ruling in a labor case. In a Rule 45 review, the Court examines the correctness of the CA decision in contrast with the review of jurisdictional errors under Rule 65. Furthermore, Rule 45 limits the review to questions of law. In ruling for legal correctness, the Court views the CA decision in the same context that the petition for certiorari was presented to the CA. Hence, the Court has to examine the CA decision from the prism of whether the CA correctly determined the presence or absence of grave abuse of discretion in the NLRC decision. [27] In labor cases, grave abuse of discretion may be ascribed to the NLRC when its findings and conclusions are not supported by substantial evidence. [28] Thus, if the NLRC's ruling has basis in the evidence and the applicable law and jurisprudence, then no grave abuse of discretion exists and the CA should so declare and, accordingly, dismiss the petition. [29] Otherwise stated, a Rule 45 petition can prosper only if the CA failed to correctly determine whether the NLRC gravely abused its discretion. [30] Viewed from these lenses, the Court finds that the NLRC Decision in this case was s