ST. MARTIN FUNERAL HOMES vs.

NATIONAL LABOR RELATIONS COMMISSION

295 SCRA 494

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?

Ruling:

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.