Can the CA re-examine the labor court's factual findings?

In one case (G.R. No. 207354. January 10, 2018), the Supreme Court took the opportunity to clarify certain doctrines regarding the review of factual findings by the Court of Appeals.

Factual findings of labor officials exercising quasi-judicial functions are accorded great respect and even finality by the courts when the findings are supported by substantial evidence. Substantial evidence is "the amount of relevant evidence which a reasonable mind might accept as adequate to support a conclusion." Thus, in labor cases, the issues in petitions for certiorari before the Court of Appeals are limited only to whether the National Labor Relations Commission committed grave abuse of discretion.

However, this does not mean that the Court of Appeals is conclusively bound by the findings of the National Labor Relations Commission. If the findings are arrived at arbitrarily, without resort to any substantial evidence, the National Labor Relations Commission is deemed to have gravely abused its discretion:

On this matter, the settled rule is that factual findings of labor officials, who are deemed to have acquired expertise in matters within their jurisdiction, are generally accorded not only respect but even finality by the courts when supported by substantial evidence, i.e., the amount of relevant evidence which a reasonable mind might accept as adequate to support a conclusion. We emphasize, nonetheless, that these findings are not infallible. When there is a showing that they were arrived at arbitrarily or in disregard of the evidence on record, they may be examined by the courts. The [Court of Appeals] can then grant a petition for certiorari if it finds that the [National Labor Relations Commission], in its assailed decision or resolution, has made a factual finding that is not supported by substantial evidence. It is within the jurisdiction of the [Court of Appeals], whose jurisdiction over labor cases has been expanded to review the findings of the [National Labor Relations Commission].

The Court of Appeals may also review factual findings if quasi­ judicial agencies' findings are contradictory to its own findings. Thus, it must re-examine the records to determine which tribunal's findings were supported by the evidence.

In one case, the Labor Arbiter and the National Labor Relations Commission made contradictory factual findings. Thus, it was incumbent on the Court of Appeals to re-examine their findings to resolve the issues before it. The Court of Appeals also found that the findings of the National Labor Relations Commission were not supported by substantial evidence, and therefore, were rendered in grave abuse of discretion.

Thus, in the determination of whether the National Labor Relations Commission committed grave abuse of discretion, the Court of Appeals may re-examine facts and re-assess the evidence. However, its findings may still be subject to review by the Supreme Court.

The High Court noted that in cases when the Court of Appeals acts as an appellate court, it is still a trier of facts. Questions of fact may still be raised by the parties. If the parties raise pure questions of law, they may directly file with the Highest Court of the Land. Moreover, contradictory factual findings between the National Labor Relations Commission and the Court of Appeals do not automatically justify the Supreme Court's review of the factual findings. They merely present a prima facie basis to pursue the action before the High Court. The need to review the Court of Appeals' factual findings must still be pleaded, proved, and substantiated by the party alleging their inaccuracy. The Supreme Court likewise retains its full discretion to review the factual findings. (G.R. No. 207354. January 10, 2018)