SC Emphasize the Conclusiveness of NLRC Decisions
“Findings of quasi-judicial bodies like the NLRC, and affirmed by the Court of Appeals in due course, are conclusive on this Court, which is not a trier of facts,” the Supreme Court said.
The Court in a January 2012 decision reiterate once more and emphasize the ruling that findings of fact of administrative agencies and quasi-judicial bodies, which have acquired expertise because their jurisdiction is confined to specific matters, are generally accorded not only respect, but finality when affirmed by the Court of Appeals.
“Such findings deserve full respect and, without justifiable reason, ought not to be altered, modified or reversed,” the Court elaborate.
The case stems from an illegal dismissal under the first contract and for failure to deploy under a second contract of an OFW worker, who hired as Third Assistant Engineer of a vessel for a period of nine (9) months. For nearly three 93) months of rendering service, the worker was ordered to disembark the vessel and repatriated back to Manila for no reason.
Upon his return, he immediately proceeded to the agency and transferred with another vessel under the same terms and conditions of the first contract. The second contract was approved by the POEA, who, without knowledge of the deployment, certified the second employment contract.
Despite the commencement of the second contract, the employer failed to deploy the worker.
Before compulsory arbitration, the Labor Arbiter found the first contract entered into by and between the worker and the employer to have been novated by the execution of the second contract.
“[T]his office would like to make it clear that the first contract entered into by and between the complainant and the respondents is deemed to have been novated by the execution of the second contract. In other words, respondents cannot be held liable for the first contract but are clearly and definitely liable for the breach of the second contract,” the Labor Arbiter ruled.
This ruling was later affirmed by the Court of Appeals, and which the Supreme Court concur that there was a novation of the first employment contract.
The Court further stressed that equally settled is the rule 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 justify a conclusion. (Stolt-Nielsen Transportation Group, Inc. vs. Medequillo, Jr., G.R. No. 177498, January 18, 2012)
Research, Information and Publications Division
National Labor Relations Commission