PFIZER, INC. AND MARIA ANGELICA B. LLEANDER, PETITIONERS, VS. EDWIN V. GALAN, RESPONDENT.

Pfizer versus Galan

The Case

This is a labor case that reached the Supreme Court through a petition for review on certiorari. Pfizer, Incorporated and its Human Resource Director, Maria Angelica B. Lleander, are the petitioners. Edwin V. Galan, a former employee of Pfizer, is the respondent. Galan was dismissed on the ground of loss of trust and confidence, and he sued for illegal dismissal. The case matters because it fixes the narrow gate through which a labor decision may be challenged before the Court of Appeals: the extraordinary writ of certiorari reaches only errors of jurisdiction or grave abuse of discretion, never a re-weighing of the facts.

Procedural History

Galan filed a complaint for illegal dismissal with the Regional Arbitration Branch in Zamboanga City. The Labor Arbiter found that he was illegally dismissed and awarded him backwages, thirteenth month pay, incentives, reimbursement of expenses, and attorney's fees in the total sum of 2,052,013.50 pesos. On appeal, the National Labor Relations Commission affirmed the Labor Arbiter. The petitioners' motion for reconsideration was denied, and the Commission's decision became final and executory. A writ of execution was then issued.

The petitioners went to the Court of Appeals on a petition for certiorari under Rule 65. The Court of Appeals dismissed the petition for having been filed beyond the sixty-day period. The petitioners brought that dismissal to the Supreme Court, which set aside the dismissal and remanded the case to the Court of Appeals for further proceedings. On remand, the Court of Appeals denied the petition and affirmed the resolutions of the National Labor Relations Commission, holding that there was no deliberate attempt on the respondent's part to defraud his employer. The petitioners' motion for reconsideration was denied. Hence, this petition for review on certiorari before the Supreme Court.

Facts

Pfizer, Incorporated is a domestic corporation engaged in the manufacture of medicines, which it sells through distributors who deliver them to retail drugstores nationwide. Maria Angelica B. Lleander was its Human Resource Director. Edwin V. Galan was hired in August 1982 as a professional sales representative, commonly called a medical representative. He received several company awards and was promoted in 1986 to District Manager for Mindanao, continuing to garner awards for exceeding the company's sales targets.

In September 1997, Pfizer issued a memorandum requiring Galan to explain his unauthorized use of the company's vehicle and his questionable expense claims, and to comment on the doubtful liquidation of his cash advance of 5,000 dollars incurred during an official trip to Indonesia. He submitted his explanation, a formal investigation was conducted, and he was preventively suspended.

On October 31, 1997, Lleander sent Galan a notice of termination on the ground of loss of trust and confidence. Galan then filed his complaint for illegal dismissal against Pfizer and Lleander.

Issues

• Whether or not the Court of Appeals erred in denying the petitioners' petition for certiorari against the resolutions of the National Labor Relations Commission.
• Whether or not the Court of Appeals, in a labor case, may review the factual findings of the Labor Arbiter and the National Labor Relations Commission in a petition for certiorari.
• Whether or not the dismissal of Galan for loss of trust and confidence was justified.

Applicable Provisions

Section 4, Rule 65 of the 1997 Rules of Civil Procedure, as amended, fixes the period within which a petition for certiorari must be filed, and the Court of Appeals invoked it when it first dismissed the petition:

Section 4. When and where petition filed. The petition shall be filed not later than sixty (60) days from notice of the judgment or resolution. In case a motion for reconsideration or new trial is timely filed, whether such motion is required or not, the sixty (60) day period shall be counted from notice of the denial of said motion.

This provision bears on the case because the appellate court's first dismissal rested on the sixty-day period, and the Supreme Court later set that dismissal aside and remanded the case for further proceedings.

Ruling

The Supreme Court denied the petition and affirmed the Court of Appeals in toto. On the first issue, the Court held that in labor cases the appellate court's jurisdiction to review a decision of the National Labor Relations Commission in a petition for certiorari is confined to issues of jurisdiction or grave abuse of discretion. The extraordinary writ of certiorari issues only for the correction of errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction; its sole function is to keep the inferior tribunal within the bounds of its jurisdiction or to prevent it from committing grave abuse of discretion.

On the second issue, the Court laid down two jurisprudential rules of long standing. First, factual issues are beyond the scope of certiorari because they do not involve any jurisdictional issue. Second, the factual findings of the National Labor Relations Commission affirming those of the Labor Arbiter, when devoid of any unfairness or arbitrariness, are accorded respect if not finality by the Court of Appeals. Where the findings of the Labor Arbiter are affirmed by the National Labor Relations Commission and the Court of Appeals, they are deemed binding, final, and conclusive upon the Supreme Court. It is not the function of the Supreme Court to inquire into the correctness of the evaluation of the evidence which was the basis for the labor official's ruling.

On the third issue, the Court sustained the findings of fact by the labor agencies and the Court of Appeals, which found no deliberate attempt on the respondent's part to defraud his employer. Those findings warranted the dismissal of the petitioners' complaint for loss of trust and confidence against the respondent.

Doctrine

A Bar candidate should retain three rules. First, in labor cases, a petition for certiorari before the Court of Appeals is confined to issues of jurisdiction or grave abuse of discretion; it is not a vehicle for reviewing the correctness of factual findings. Second, factual findings of the National Labor Relations Commission affirming those of the Labor Arbiter, when devoid of any unfairness or arbitrariness, are accorded respect if not finality by the Court of Appeals. Third, where the Labor Arbiter, the National Labor Relations Commission, and the Court of Appeals all agree on the facts, those findings are binding, final, and conclusive upon the Supreme Court, which will not disturb the findings of officials who have gained expertise in their specialized field.

Disposition

The Supreme Court denied the petition and affirmed in toto the decision of the Court of Appeals, with costs against the petitioners; Galan prevailed.

Remember This

Memorize this line: certiorari in labor cases reaches only jurisdiction or grave abuse of discretion, never the facts. Examiners use this case to test whether a petitioner may convert a Rule 65 petition into an appeal that re-weighs the evidence, and to test the conclusiveness of concurring factual findings of the Labor Arbiter, the National Labor Relations Commission, and the Court of Appeals.