Wednesday, April 16, 2014

Principle of Finality and Conclusiveness of the Decisions of the Labor Tribunals; Exceptions to it.

While the factual findings of an administrative agency is normally accorded great respect, and when warranted, even finality by the appellate courts, they may be reviewed in certain cases, as when there is lack of  substantial basis in fact or in law.
This issue is discussed in part in the below case.
In this case, the Petitioner assails the decision of the Court of Appeals reversing the consistent factual findings of her constructive dismissal by both the Labor Arbiter and the NLRC, reasoning they are conclusive upon the Court.
In rejecting this proposition, the Court held:
Petitioner faults the Court of Appeals for reversing the factual findings of the Labor Arbiter as affirmed by the NLRC that she was constructively dismissed relying on the principle of finality and conclusiveness of the decisions of the labor tribunals. However, it is well-settled that for want of substantial basis, in fact or in law, factual findings of an administrative agency, such as the NLRC, cannot be given the stamp of finality and conclusiveness normally accorded to it, as even decisions of administrative agencies which are declared "final" by law are not exempt from the judicial review when so warranted.16

In administrative proceedings, the quantum of proof required is substantial evidence, which is more than a mere scintilla of evidence, but such amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion.17 The Court of Appeals may review the factual findings of the NLRC and reverse its ruling if it finds that the decision of the NLRC lacks substantial basis.

In the same vein, factual findings of the Court of Appeals are generally not subject to this Court’s review under Rule 45. However, the general rule on the conclusiveness of the factual findings of the Court of Appeals is also subject to well-recognized exceptions such as where the Court of Appeals’ findings of facts contradict those of the lower court, or the administrative bodies, as in this case.18 All these considered, we are compelled to make a further calibration of the evidence at hand.” (Underscoring added)
Ma. Finina E. Vicente vs. The Hon. Court Of Appeals, et al. G.R. No. 175988,  August 24, 2007
Read the full text of the case here.

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