Supreme Court may look into factual issues in labor cases
"If the Labor Arbiter and the National Labor Relations Commission (NLRC) sided with the terminated employee, but the decision was reversed by the Court of Appeals (CA), can the terminated employee still elevate her case with the Supreme Court? I have read before that the Supreme Court is not a trier of facts. So, I am just wondering if elevating such case in the Supreme Court can still be an option.
As a general rule, the Supreme Court does not delve on questions of fact because the high court is not a trier of facts. Corollary, questions of fact are addressed during the trial of the case when it is still before the quasi-judicial agencies and the lower courts or when the matter is raised on appeal before the Court of Appeals.In certain cases, however, the Supreme Court opts to exercise its discretion of re-examining the facts affecting the legal matters brought before it especially if justice will be best served. For instance, in labor cases, while the Supreme Court often does not pass upon matters which deal with questions of fact, the high court can elect to revisit said case if there are varying findings by the Labor Arbiter, the NLRC and the Court of Appeals. As held in the case of South East International Rattan, Inc. and/or Agbay vs. Coming (GR 186621, March 12, 2014, Ponente: Former Associate Justice Martin Villarama Jr.):
“The issue of whether or not an employer-employee relationship exists in a given case is essentially a question of fact. As a rule, this Court is not a trier of facts and this applies with greater force in labor cases. Only errors of law are generally reviewed by this Court. This rule is not absolute, however, and admits of exceptions. For one, the Court may look into factual issues in labor cases when the factual findings of the Labor Arbiter, the NLRC, and the CA are conflicting. Here, the findings of the NLRC differed from those of the Labor Arbiter and the CA, which compels the Court’s exercise of its authority to review and pass upon the evidence presented and to draw its own conclusions therefrom.” (Emphasis supplied)The Supreme Court likewise explained in the case of General Milling Corporation vs. Viajar (GR 181738, Jan. 30, 2013, Ponente: Former Associate Justice Bienvenido Reyes):
“The rule is that factual findings of quasi-judicial agencies such as the NLRC are generally accorded not only respect, but at times, even finality because of the special knowledge and expertise gained by these agencies from handling matters falling under their specialized jurisdiction. It is also settled that this Court is not a trier of facts and does not normally embark in the evaluation of evidence adduced during trial. This rule, however, allows for exceptions. One of these exceptions covers instances when the findings of fact of the trial court, or of the quasi-judicial agencies concerned, are conflicting or contradictory with those of the CA. When there is a variance in the factual findings, it is incumbent upon the Court to re-examine the facts once again.” (Emphasis supplied)Thus, a terminated employee may elevate her case before the Supreme Court, even if it involves questions of fact, when there is clear disparity in the findings of the Labor Arbiter and the NLRC and that of the Court of Appeals, provided, however, that such remedy is still permitted pursuant to pertinent provisions of our laws as well as of the Rules of Court.We hope that we were able to answer your queries. This advice is based solely on the facts you have narrated and our appreciation of the same. Our opinion may vary when other facts are changed or elaborated.Editor’s note: Dear PAO is a daily column of the Public Attorney’s Office. Questions for Chief Acosta may be sent to "
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"Supreme Court may look into factual issues in labor cases"
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and updated on 15 September 2021