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St. Martin Funeral Homes v. NLRC, G.R. No. 130866 (1998) R.A. 7902

The Supreme Court held that while the petitioner correctly filed a motion for reconsideration with the NLRC, they should have filed an appeal or petition for certiorari to the Court of Appeals rather than directly to the Supreme Court. Historically, decisions of the NLRC could be appealed to the Secretary of Labor and then the Office of the President. However, the new rules did not specify appellate review procedures for NLRC decisions. While the Supreme Court has an underlying power for judicial review of agency decisions on questions of law and jurisdiction, appeals should follow the typical hierarchy of courts, with the Court of Appeals as the proper court in this case. The case was remanded to the Court of Appeals.

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121 views1 page

St. Martin Funeral Homes v. NLRC, G.R. No. 130866 (1998) R.A. 7902

The Supreme Court held that while the petitioner correctly filed a motion for reconsideration with the NLRC, they should have filed an appeal or petition for certiorari to the Court of Appeals rather than directly to the Supreme Court. Historically, decisions of the NLRC could be appealed to the Secretary of Labor and then the Office of the President. However, the new rules did not specify appellate review procedures for NLRC decisions. While the Supreme Court has an underlying power for judicial review of agency decisions on questions of law and jurisdiction, appeals should follow the typical hierarchy of courts, with the Court of Appeals as the proper court in this case. The case was remanded to the Court of Appeals.

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Keyan Motol
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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St. Martin Funeral Homes v. NLRC, G.R. No. 130866 (1998); R.A.

7902

Facts: Respondent (Arcayos) was summarily dismissed by St. Martin Funeral Homes for
misappropriating funds worth Php 38,000 which was supposed to be taxes paid to the Bureau of
Internal Revenue (BIR). Alleging that the dismissal was illegal, respondent filed a case against
St. Martin Funeral Homes in the National Labor Relations Commission (NLRC).

Petitioner’s (St. Martin Funeral Homes) contention is that the respondent is not an employee due
to the lack of an employer-employee contract. In addition, respondent is not listed on St.
Martin’s monthly payroll.
The labor arbiter ruled in favor of petitioner, confirming that indeed, there was no employer-
employee relationship between the two and hence, there could be no illegal dismissal in such a
situation.

The respondent appealed to the secretary of NLRC who set aside the decision and remanded the
case to the labor arbiter. Petitioner filed a motion for reconsideration, but was denied by the
NLRC. Now, petitioners appealed to the Supreme Court – alleging that the NLRC committed
grave abuse of discretion.

Issue: Whether or not the petitioner’s appeal/petition for certiorari was properly filed in the
Supreme Court.

Held: No.

Historically, decisions from the NLRC were appealable to the Secretary of Labor, whose
decisions are then appealable to the Office of the President. However, the new rules do not
anymore provide provisions regarding appellate review for decisions rendered by the NLRC.

However in this case, the Supreme Court took it upon themselves to review such decisions from
the NLRC by virtue of their role under the check and balance system and the perceived intention
of the legislative body who enacted the new rules.

“It held that there is an underlying power of the courts to scrutinize the acts of such agencies on
questions of law and jurisdiction even though no right of review is given by statute; that the
purpose of judicial review is to keep the administrative agency within its jurisdiction and protect
the substantial rights of the parties; and that it is that part of the checks and balances which
restricts the separation of powers and forestalls arbitrary and unjust adjudications.”

The petitioners rightfully filed a motion for reconsideration, but the appeal or certiorari should
have been filed initially to the Court of Appeals – as consistent with the principle of hierarchy of
courts. As such, the Supreme Court remanded the case to the Court of Appeals.

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