San Miguel Corporation vs. Secretary of Labor, G.R. No.

L-39195, May 16, 1975

FACTS:
Respondent Gregorio Yanglay, Jr. is employed as an operator in the crown cork department of petitioner
San Miguel Corporation’s Metal Closure and Lithography Plant. Yanglay was dismissed due to illegal
trafficking of company medicines. During the investigation conducted by the management, Yanglay
contended that he had not violated any rule of the company. Yanglay filed a complaint with the NLRC
alleging that there was no evidence to justify his dismissal and the case was scheduled for mediation.
Mediator-fact finder Enrique C. Cruz admitted that the San Miguel Corporation had not committed unfair
labor practice and recommended Yanglay's reinstatement. The NLRC adopted Cruz’s report in its
decision. Petitioner moved for the reconsideration of the decision but the same was denied by the
Secretary of Labor.

ISSUE:
1. Whether or not this Court has jurisdiction to review the decisions of the NLRC and the Secretary
of Labor?
2. Whether or not Yanglay’s dismissal from employment was justified?

RULING:
1. Yes. It is generally understood that as to administrative agencies exercising quasi-judicial or
legislative power there is an underlying power in 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. The
purpose of judicial review is to keep the administrative agency within its jurisdiction and protect
substantial rights of parties affected by its decisions. It is part of the system of checks and
balances which restricts the separation of powers and forestalls arbitrary and unjust
adjudications.
2. Taking into account the circumstances of the case, particularly Yanglay's initial attitude of
confessing that his error was dictated by necessity and his promise not to repeat the same
mistake, the Court is of the opinion that his dismissal was a drastic punishment. The misconduct
of employees or workers in misrepresenting to the company that they needed medicines when in
fact their purpose was to sell the same should not be tolerated. For such misrepresentations or
deceptions, appropriate disciplinary action should be taken against them.