G.R. No. 168749 - Sugarsteel Industrial, Inc. vs. Albina

On August 16, 1996, at approximately 4:00 a.m., a clog-up occurred at the kettle sheet guide while the petitioners were on duty in their respective areas.
As a consequence, twenty (20) GI sheets became clogged inside the kettle, resulting in damage to the property of one of the respondents.
Subsequently, a memorandum was issued by Mr. Ben S. Yapjoco, the manager of the private respondent, requiring the petitioners to submit a written explanation regarding the incident to avoid action for gross negligence.
The petitioners submitted their respective explanations.
On August 20, 1996, a follow-up memorandum instructed all petitioners to attend a conference concerning the incident.
On August 26, 1996, individual suspension notices were issued pending the final resolution on the matter.
On August 29, 1996, individual notices of termination were sent to the petitioners stating that, after an investigation, they were found guilty of gross neglect of duty, thereby justifying their dismissal.

On April 27, 1998, the Labor Arbiter ruled that although the dismissal was justified due to the respondents’ gross negligence, the petitioners were directed to pay separation pay at the rate of 1/2 month per year of service.
On appeal, the National Labor Relations Commission (NLRC) upheld the Labor Arbiter’s decision on December 23, 1998, dismissing the respondents’ appeal on the ground that the appeal did not strictly conform to the grounds enumerated in Article 223 of the Labor Code.
On May 8, 2000, the NLRC denied a motion for reconsideration from the respondents, reiterating the dismissal of their appeal based on failure to comply with the proper appeal procedures.

The respondents, aggrieved by the NLRC’s decisions, petitioned the CA for certiorari, alleging that the NLRC committed grave abuse of discretion in affirming the dismissal of the petitioners by misapplying the requirements of Article 223 of the Labor Code.
The petitioners, in turn, maintained that the CA’s review should have been limited only to issues of jurisdictional error, without reassessing the NLRC’s factual findings.

Did the Court of Appeals exceed its jurisdiction by re-assessing and overturning the factual findings of the NLRC in its review for absence or excess of jurisdiction through a petition for certiorari?

Whether the CA’s power to review evidence and pass upon the facts contradicts the principle that the factual findings of labor tribunals (such as the NLRC) are final and binding when supported by substantial evidence.
Whether the petitioners failed to discharge the burden of proving that the dismissal of the respondents was for just and valid cause under Article 282 (b) of the Labor Code, which requires gross and habitual negligence.
Whether the NLRC’s dismissal of the respondents’ appeal on a technical basis under Article 223 of the Labor Code, by narrowly interpreting its grounds, amounted to grave abuse of discretion.