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ST. MARTIN FUNERAL HOME v. NATIONAL LABOR RELATIONS MARTINEZ

This case has been cited 54 times or more.

2015-09-23
JARDELEZA, J.
The power of the Court of Appeals to review NLRC decisions via a Petition for Certiorari under Rule 65 of the Revised Rules of Court was settled in our decision in St. Martin Funeral Home v. NLRC.[60] The general rule is that certiorari does not lie to review errors of judgment of the trial court, as well as that of a quasi-judicial tribunal. In certiorari proceedings, judicial review does not go as far as to examine and assess the evidence of the parties and to weigh their probative value.[61] However, this rule admits of exceptions. In Globe Telecom, Inc. v. Florendo-Flores,[62] we stated:In the review of an NLRC decision through a special civil action for certiorari, resolution is confined only to issues of jurisdiction and grave abuse of discretion on the part of the labor tribunal. Hence, the Court refrains from reviewing factual assessments of lower courts and agencies exercising adjudicative functions, such as the NLRC. Occasionally, however, the Court is constrained to delve into factual matters where, as in the instant case, the findings of the NLRC contradict those of the Labor Arbiter.
2015-01-21
PERALTA, J.
In its Resolution dated May 27, 2010, the CA explained that it resolved the issues raised by the respondent even though the decision of the NLRC had lapsed as contemplated in Section 223 of the Labor Code, on the ground that she filed on time a petition for certiorari under Rule 65 and the allegations contained therein are jurisdictional and with due process considerations, citing this Court's decision on St. Martin Funeral Home v. NLRC.[11]
2013-08-28
BERSAMIN, J.
In St. Martin Funeral Home v. National Labor Relations Commission,[13] the Court has clarified that parties seeking the review of decisions of the NLRC should file a petition for certiorari in the CA on the ground of grave abuse of discretion amounting to lack or excess of jurisdiction on the part of the NLRC. Thereafter, the remedy of the aggrieved party from the CA decision is an appeal via petition for review on certiorari.[14]
2013-06-10
MENDOZA, J.
Section 14, Rule VII of the 2011 NLRC Rules of Procedure provides that decisions, resolutions or orders of the NLRC shall become final and executory after ten (10) calendar days from receipt thereof by the parties, and entry of judgment shall be made upon the expiration of the said period.[10] In St. Martin Funeral Home v. NLRC,[11] however, it was ruled that judicial review of decisions of the NLRC may be sought via a petition for certiorari before the CA under Rule 65 of the Rules of Court; and under Section 4 thereof, petitioners are allowed sixty (60) days from notice of the assailed order or resolution within which to file the petition. Hence, in cases where a petition for certiorari is filed after the expiration of the 10-day period under the 2011 NLRC Rules of Procedure but within the 60-day period under Rule 65 of the Rules of Court, the CA can grant the petition and modify, nullify and reverse a decision or resolution of the NLRC.
2013-02-18
BERSAMIN, J.
And, secondly, the ruling in National Federation of Labor v. Laguesma reiterates St. Martin's Funeral Home v. National Labor Relations Commission,[23] where the Court has pronounced that the special civil action of certiorari is the appropriate remedy from the decision of the National Labor Relations Commission (NLRC) in view of the lack of any appellate remedy provided by the Labor Code to a party aggrieved by the decision of the NLRC. Accordingly, any decision, resolution or ruling of the DOLE Secretary from which the Labor Code affords no remedy to the aggrieved party may be reviewed through a petition for certiorari initiated only in the CA in deference to the principle of the hierarchy of courts.
2011-04-13
NACHURA, J.
as when after the lapse of the reglementary period to appeal, no appeal has been perfected.[19] The period or manner of appeal from the NLRC to the CA is governed by Rule 65, pursuant to the ruling of this Court in St. Martin Funeral Home v. National Labor Relations Commission.[20] Section 4 of Rule 65, as amended, states that the
2010-11-15
PERALTA, J.
Subsequently, in a Resolution[17] dated December 9, 1998, we referred the petition to the CA in accordance with the St. Martin Funeral Home v. National Labor Relations Commission[18] ruling.
2010-03-03
NACHURA, J.
In the landmark case of St. Martin Funeral Home v. NLRC,[20] we ruled that judicial review of decisions of the NLRC is sought via a petition for certiorari under Rule 65 of the Rules of Court, and the petition should be filed before the CA, following the strict observance of the hierarchy of courts. Under Rule 65, Section 4,[21] petitioners are allowed sixty (60) days from notice of the assailed order or resolution within which to file the petition. Thus, although the petition was not filed within the 10-day period, petitioners reasonably filed their petition for certiorari before the CA within the 60-day reglementary period under Rule 65.
2008-09-11
REYES, R.T., J.
The correct remedy that should have been availed of is the special civil action of certiorari under Rule 65.  As this Court held in the case of Pure Foods Corporation v. NLRC,[39] "the party may also seasonably avail of the  special  civil  action for  certiorari,  where the tribunal, board  or officer exercising judicial functions has acted without or in excess of its jurisdiction, or with grave abuse of discretion, and praying that judgment be rendered annulling or modifying the proceedings, as the law requires, of such tribunal, board or officer."[40]  In any case, St. Martin Funeral Homes v. National Labor Relations Commission[41] settled any doubt as to the manner of elevating decisions of the NLRC to the CA by holding that "the legislative intendment was that the special civil action of certiorari was and still is the proper vehicle for judicial review of decisions of the NLRC."[42]
2008-07-09
QUISUMBING, J.
On the first issue, petitioners contend that Suganob's petition before the Court of Appeals should have been dismissed outright since he availed of the wrong remedy.  They stress that in the case of St. Martin Funeral Home v. NLRC,[12] the Court held that decisions of the NLRC should be brought to the Court of Appeals by way of a petition for certiorari under Rule 65.[13]
2008-06-17
YNARES-SATIAGO, J.
The period or manner of "appeal" from the NLRC to the Court of Appeals is governed by Rule 65 pursuant to the ruling of this Court in the case of St. Martin Funeral Home v. National Labor Relations Commission.[21] Section 4 of Rule 65, as amended, states that the "petition may be filed not later than sixty (60) days from notice of the judgment, or resolution sought to be assailed."[22]
2008-06-12
PUNO, CJ.
accordance with the ruling in St. Martin Funeral Homes v. NLRC.[16]
2008-03-14
CHICO-NAZARIO, J.
On 4 December 1996, private respondents filed a Petition for Certiorari[29] before this Court assailing the Decision and the Order of the NLRC dated 30 January 1996 and 30 October 1996, respectively. On 9 December 1998, this Court issued a Resolution[30] referring the case to the Court of Appeals conformably with its ruling in St. Martin Funeral Home v. National Labor Relations Commission.[31] The case was docketed before the appellate court as CA-G.R. SP No. 50806.
2008-02-04
SANDOVAL-GUTIERREZ, J.
Undaunted, petitioner filed a petition for certiorari with this Court. However, we referred the petition to the Court of Appeals pursuant to our ruling in St. Martin Funeral Homes v. NLRC.[5] It was docketed therein as CA-G.R. SP No. 54379.
2007-12-04
VELASCO JR., J.
On December 6, 1994, Genuino filed a petition for certiorari docketed as G.R. No. 118023 with this Court. Citibank's petition for certiorari, on the other hand, was docketed as G.R. No. 118667. In the January 27, 1999 Resolution, we referred these petitions to the CA pursuant to our ruling in St. Martin Funeral Home v. NLRC.[19]
2007-10-15
QUISUMBING, J.
Petitioners and respondents filed separate petitions, docketed as G.R. Nos. 129104 and 128798, respectively, with this Court. After the petitions were consolidated, this Court referred the case to the Court of Appeals in accordance with St. Martin Funeral Home v. NLRC.[5]
2007-10-05
CARPIO MORALES, J.
By Order of February 18, 1994, the Labor Arbiter granted SMFI et al.'s motion to dismiss and ordered the remand of the case to the grievance machinery for completion of the proceedings.[11] The Union appealed the said order to the NLRC by "Motion for Reconsideration/Appeal"[12] which its Second Division granted and accordingly ordered the Labor Arbiter to continue the proceedings on the Union's complaint.[13] SMFI et al. filed a Motion for Reconsideration of the NLRC order but it was denied, hence, they filed a petition for certiorari with this Court. After the parties and the Solicitor General had filed their respective pleadings, this Court, by Resolution of January 25, 1999, referred the case to the Court of Appeals pursuant to St. Martin Funeral Homes v. NLRC.[14]
2007-09-13
TINGA, J.
Respondents, for their part, argue that by virtue of the Court's pronouncement in St. Martin Funeral Homes v. NLRC,[23] the Court of Appeals is clothed with plenary authority to reverse the factual findings of the NLRC or other quasi-judicial bodies particularly when the latter's judgment is based on a misapprehension of facts when it manifestly overlooked certain relevant facts, which if properly considered would justify a different conclusion, or when it erroneously misapplied a law as is obtaining in the case at bar.[24]
2007-08-14
QUISUMBING, J.
In St. Martin Funeral Home v. NLRC,[13] we held that the special civil action of certiorari is the mode of judicial review of the decisions of the NLRC either by this Court or the Court of Appeals, but the latter court is the more appropriate forum in view of the doctrine on the hierarchy of courts and that, in the exercise of this power, the Court of Appeals can review the factual findings or the legal conclusions of the NLRC.[14]
2007-01-31
CARPIO MORALES, J.
On the first issue, contrary to the contention of the corporation (hereafter petitioner), it was within the jurisdiction of the Court of Appeals, whose jurisdiction over labor cases has been expanded to review the findings of the NLRC.  Thus, St. Martin Funeral Home v. NLRC[23] teaches: . . . [E]ver since appeals from the NLRC to the Supreme Court were eliminated, the legislative intendment was that the special civil action of certiorari was and still is the proper judicial review of decisions of the NLRC.
2007-01-29
Consistent with its ruling in St. Martin Funeral Homes v. NLRC,[15] the Court, in its Resolution of February 29, 1999, referred Rubberworld's amended petition for certiorari and its supplement to the CA for appropriate action, whereat it was docketed as CA- G.R. SP No. 53356.
2006-10-17
GARCIA, J.
On December 7, 1998, the Court issued a Resolution referring the three aforesaid petitions to the CA  for appropriate action and disposition, pursuant to St. Martin Funeral Homes v. NLRC.[13]  In the CA, the Bank's petition, PVB v. NLRC, et al., was docketed as CA-G.R. SP No. 51218, that of the  Union, PVBEU-NUBE v. NLRC, et al., was docketed as CA-G.R. SP No. 51219, and that of herein petitioners' Lady Lydia Cornista Domingo, et al. v. NLRC, et al., was docketed as CA-G.R. SP No. 51220. The three (3) petitions were thereafter consolidated.
2006-08-29
YNARES-SANTIAGO, J.
On June 11, 1997, petitioner filed a complaint[9] with the NLRC which was docketed as NLRC OCW Case No. 6-838-97-L praying for an award of disability benefits, share in the insurance proceeds, moral damages and attorney's fees. On September 29, 1997, Acting Executive Labor Arbiter Voltaire A. Balitaan dismissed the complaint on the ground of prescription. Petitioner appealed the decision with the NLRC. On March 31, 1998, the NLRC promulgated its decision[10] finding the appeal to be without merit and ordered its dismissal. When the motion for reconsideration[11] was denied by the NLRC in its resolution dated June 29, 1998,[12] petitioner filed a petition for certiorari with this Court. On December 2, 1998, we resolved to refer the case to the Court of Appeals pursuant to our ruling in St. Martin Funeral Home v. National Labor Relations Commission.[13]
2006-08-10
SANDOVAL-GUTIERREZ, J.
Asian Terminals then seasonably filed a petition for certiorari with this Court. Pursuant to our ruling in St. Martin's Funeral Home v. National Labor Relations Commission,[4] the petition was referred to the Court of Appeals. On July 13, 2001, it rendered a Decision dismissing the petition and affirming the NLRC assailed judgment.
2006-05-04
TINGA, J.
Pursuant to the ruling of this Court in St. Martin Funeral Homes v. NLRC,[12] the case was referred to the Court of Appeals and re-docketed as CA-G.R. SP No. 50851.
2006-03-31
PUNO, J.
In St. Martin Funeral Home v. NLRC,[13] we held that all petitions for certiorari from decisions and resolutions of the NLRC, instead of being filed directly with this Court, shall be filed instead in the Court of Appeals in strict observance of the doctrine on the hierarchy of courts. This was intended to relieve the Court of the unnecessary caseload of labor cases which, more often than not, present issues important only within the particular facts and parties involved in the case. From a litigant's point of view, the measure was important in providing a valuable opportunity of having the evidence reexamined and reweighed by the Court of Appeals in the course of affirming, modifying or reversing the findings of facts and conclusions of the labor officials. The Court of Appeals was considered procedurally equipped for the purpose under Section 9 of Batas Pambansa Blg. 129, known as the Judiciary Reorganization Act, which provides, viz:SEC. 9. Jurisdiction. The Court of Appeals shall exercise:
2006-03-10
CALLEJO, SR., J.
On the first issue, we find and so hold that the decision of the NLRC had become final and executory when PPI filed its Petition for Certiorari in the CA.  PPI received a copy of the NLRC Decision on July 11, 2003 and filed the Motion for Reconsideration thereof on July 18, 2003, which motion was denied on September 30, 2003.  Under Rule VII, Section 2 of the NLRC Omnibus Rules of Procedure, the decision of the NLRC becomes final and executory after ten (10) calendar days from receipt of the same.  PPI received a copy of the NLRC decision on November 30, 2003; hence, such decision became final and executory on December 3, 2003.  Nonetheless, the Court ruled in St. Martin Funeral Home v. NLRC[63] that, although the 10-day period for finality of the NLRC decision may have elapsed as contemplated in the last paragraph of Section 223 of the Labor Code, the CA may still take cognizance of and resolve a petition for certiorari for the nullification of the decision of the NLRC on jurisdictional and due process considerations.  Indeed, the remedy of the aggrieved party from an adverse decision of the NLRC is to timely file a motion for reconsideration as a precondition for any further or subsequent remedy, and if the motion is denied, such party may file a special civil action in accordance with law and jurisprudence considering that these matters are inseparable in resolving the main issue of whether the NLRC committed grave abuse of discretion.
2006-02-09
CHICO-NAZARIO, J.
During the pendency of petitioner's motion for reconsideration, the decision in St. Martin's Funeral Homes v. National Labor Relations Commission[6] was promulgated.  Following the ruling in said case, petitioner's motion for reconsideration of our resolution dated 06 July 1998 was remanded to the Court of Appeals for proper disposition.
2006-01-31
CARPIO MORALES, J.
After respondents and the NLRC, through the Office of the Solicitor General, filed their respective Comments,[26] this Court referred the petition to the CA by Resolution[27] of December 9, 1998, in view of its ruling in St. Martin Funeral Homes v. NLRC.[28]
2005-08-22
CHICO-NAZARIO, J.
Aggrieved, herein petitioner commenced, on 14 November 1994, a Petition for Certiorari before the Supreme Court.[6] The subject petition, however, was referred to the Court of Appeals for appropriate action and disposition per resolution[7] of this Court dated 07 December 1998, in accordance with the ruling in St. Martin Funeral Home v. NLRC.[8]
2005-08-14
AUSTRIA-MARTINEZ, J.
After the submission of the responsive pleadings and memoranda, we referred the petition, in accordance with St. Martin Funeral Homes vs. NLRC,[15] to the CA which, on September 27, 2000, modified the decision of the NLRC by declaring MERALCO as the direct employer of the individual respondents.
2005-08-12
QUISUMBING, J.
Secondly, the general rule is that the findings of fact by the NLRC are deemed binding and conclusive. However, where, as in the instant case, the findings of fact by the NLRC contradict those of the Labor Arbiter, a departure from the general rule is warranted.  In St. Martin Funeral Home v. NLRC,[10] we said that the Court of Appeals can review the factual findings of the NLRC in a special civil action for certiorari.[11]
2005-08-11
CARPIO MORALES, J.
By Resolution of February 3, 1999,[9] this Court, consistent with its pronouncement in St. Martin Funeral Home v. NLRC et al.,[10] referred petitioner's petition bearing docket G.R. No. 136416 to the Court of Appeals (CA) for appropriate action and disposition.
2005-07-14
AUSTRIA-MARTINEZ, J.
After the submission of the responsive pleadings and memoranda, we referred the petition, in accordance with St. Martin Funeral Homes vs. NLRC,[15] to the CA which, on September 27, 2000, modified the decision of the NLRC by declaring MERALCO as the direct employer of the individual respondents.
2005-07-12
QUISUMBING, J.
Secondly, the general rule is that the findings of fact by the NLRC are deemed binding and conclusive. However, where, as in the instant case, the findings of fact by the NLRC contradict those of the Labor Arbiter, a departure from the general rule is warranted. In St. Martin Funeral Home v. NLRC,[10] we said that the Court of Appeals can review the factual findings of the NLRC in a special civil action for certiorari.[11]
2005-06-30
SANDOVAL-GUTIERREZ, J.
On June 23, 1998, petitioner filed with this Court a petition for certiorari assailing the Labor Secretary's Orders.  Pursuant to our ruling in St. Martin Funeral Home vs.The National Labor Relations Commission, et al.,[4] we referred the petition to the Court of Appeals for its appropriate action and disposition.
2005-02-28
AUSTRIA-MARTINEZ, J.
In accordance with St. Martin Funeral Homes vs. NLRC,[15] we referred the petition to the Court of Appeals which, on June 30, 1999, set aside the decision of the NLRC and reinstated the decision of the POEA.[16] The Court of Appeals held that respondents were illegally dismissed since the petitioners failed to substantiate their claim that respondents voluntarily resigned from employment. It ruled that the quitclaims are not sufficient to show valid terminations. Anent non-compliance with the formal requirements of the petition, the Court of Appeals, adopting the observation of the Solicitor General, held that the case is an exception to the rule on strict adherence to technicality.
2005-02-17
SANDOVAL-GUTIERREZ, J.
Petitioners then filed a motion for reconsideration but was denied by the NLRC in a Resolution dated April 30, 1998. Hence, they filed with this Court a petition for certiorari which we referred to the Court of Appeals pursuant to our ruling in St. Martin's Funeral Home vs. NLRC.[4]
2005-01-17
SANDOVAL-GUTIERREZ, J.
Hence, respondent filed with this Court a petition for certiorari under Rule 65 of the 1997 Rules of Civil Procedure, as amended.  Pursuant to our Decision in St. Martin Funeral Homes vs. NLRC,[15] we referred the petition to the Court of Appeals.