St. Martin Funeral Homes vs.

NLRC

G.R. No. 130866

September 16, 1998

Doctrine:

All references in the amended Section 9 of B.P. No. 129 to supposed appeals from the NLRC to the
Supreme Court are interpreted and hereby declared to mean and refer to petitions for certiorari under Rule
65. Consequently, all such petitions should hence forth be initially filed in the Court of Appeals in strict
observance of the doctrine on the hierarchy of courts as the appropriate forum for the relief desired.

Facts:

Respondent Arcayos was summarily dismissed by St. Martin Funeral Homes as Operations Manager for
misappropriating funds worth Php 38,000. Alleging that the dismissal was illegal, respondent filed a case
against St. Martin Funeral Homes in the National Labor Relations Commission (NLRC).

L.A ruled in favor of St. Martin confirming that indeed, there was no employer-employee relationship
between the two and hence, there could be no illegal dismissal in such a situation.

Arcayos appealed to the 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.

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.