Palomado v. NLRC
G.R. No. 96520 (June 28, 1996)
Facts:
The case involves Restituto C. Palomado, who filed a complaint against Marling Rice Mill, Mario Tan Teng Kuan, and Rolando Tan for alleged illegal dismissal, underpayment of wages, and various benefits. Palomado claimed he was employed as a truck driver from January 2, 1970, until his dismissal in August 1987. He alleged that Rolando Tan, the manager/operator of Marling Rice Mill, dismissed him without cause after promising to retain him as the driver of a new truck. Palomado asserted that he suffered financial losses due to this dismissal and sought compensation for unpaid wages, overtime, holiday pay, and separation benefits.
The labor arbiter, after reviewing the position papers and supporting documents, concluded that the case could be decided without formal hearings. The arbiter found that Palomado had not been employed by Marling Rice Mill since July 1979, as evidenced by a certification from the Social Security System (SSS) indicating that he was no longer listed as an employee after that date. The arbiter also noted that Marling Rice Mill ceased operations in 1987 following the death of its owner, Mario Tan Teng Kuan.
In contrast, Rolando Tan argued that he was not the owner or manager of Marling Rice Mill and that Palomado had never been employed by his own business, R. S. Ricemill, which started operations in 1986. The labor arbiter found no employer-employee relationship between Palomado and Rolando Tan, leading to the dismissal of Palomado's claims.
Palomado appealed the labor arbiter's decision to the National Labor Relations Commission (NLRC), which affirmed the arbiter's findings, leading to the present petition for certiorari before the Supreme Court.
Legal Issues:
- Whether the NLRC erred in affirming the labor arbiter's decision that there was no grave abuse of discretion or serious errors in the findings of fact.
- Whether the labor arbiter properly determined the absence of an employer-employee relationship between Palomado and Rolando Tan.
- Whether the procedural requirements for filing a petition for certiorari were met.
Arguments:
Petitioner (Palomado):
- Argued that the labor arbiter acted with grave abuse of discretion by not conducting formal hearings and dismissing his claims without allowing him to present evidence.
- Contended that the arbiter's reliance on the SSS certification and other documents was erroneous and that a formal hearing would have allowed for the presentation of additional evidence.
- Claimed that there existed an employer-employee relationship with Rolando Tan, who allegedly had the authority to hire and dismiss employees.
Respondents (NLRC and Rolando Tan):
- Asserted that the labor arbiter acted within his discretion by deciding the case based on the submitted position papers, as the possibility of amicable settlement was remote.
- Maintained that the evidence presented, particularly the SSS certification, clearly indicated that Palomado was not an employee after June 1979, and thus, there was no basis for his claims.
- Argued that Palomado failed to file a motion for reconsideration before seeking certiorari, which constituted a procedural defect.
Court's Decision and Legal Reasoning:
The Supreme Court dismissed Palomado's petition for lack of merit. The Court noted several procedural defects in the petition, including the incorrect invocation of Rule 43 instead of Rule 65 for certiorari and the failure to file a motion for reconsideration before seeking judicial review. The Court emphasized that certiorari is only appropriate when there is no other plain, speedy, and adequate remedy available.
The Court also reiterated that the findings of quasi-judicial bodies like the NLRC are generally accorded great respect and finality, especially when supported by substantial evidence. The Court found that the labor arbiter's decision was based on substantial evidence, including the SSS certification and payroll records, which indicated that Palomado had ceased to be an employee of Marling Rice Mill long before his complaint was filed.
Furthermore, the Court ruled that the absence of an employer-employee relationship between Palomado and Rolando Tan precluded any claims of illegal dismissal. The Court concluded that the labor arbiter and the NLRC acted correctly in dismissing the case.
Significant Legal Principles Established:
- The appropriate remedy to challenge NLRC rulings is a petition for certiorari under Rule 65, not a petition for review under Rule 43 or 45.
- A motion for reconsideration is a prerequisite to filing a certiorari petition.
- Certiorari will only lie for questions of jurisdiction or grave abuse of discretion, not for ordinary errors of law.
- The findings of fact of the NLRC are generally binding and accorded finality unless there is a clear showing of arbitrary disregard of evidence.