Department of Health vs. Nestle Philippines, Inc.

A petition for certiorari under Rule 65 of the Rules of Court is limited to correcting errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction and cannot be used to review the intrinsic correctness of administrative findings of fact or errors of judgment, as the supervisory jurisdiction of courts extends only to keeping quasi-judicial bodies within their jurisdictional bounds, not to reweighing evidence or substituting the court's judgment for that of the administrative agency.

Mymanette M. Jarra purchased a 150-gram pack of Nestle Bear Brand Powdered Filled Milk from a retail store in Quezon City on October 16, 2007. Upon opening the foil pack, she discovered objects appearing to be larvae and observed that the powder was yellowish and lumpy. The following day, Jarra filed a complaint with the DOH Consumer Arbitration Office of the National Capital Regional Office (CAO-NCR) seeking redress for the alleged distribution of adulterated food products.

• The Purchase and Discovery: On October 16, 2007, consumer Mymanette M. Jarra purchased a 150-gram foil pack of Nestle Bear Brand Powdered Filled Milk from Joy Store in San Francisco Del Monte, Quezon City. Upon opening the package, she observed objects resembling larvae and noted that the powder appeared yellowish and lumpy.
• Administrative Complaint and Laboratory Analysis: Jarra filed a complaint with the DOH Consumer Arbitration Office of the National Capital Regional Office (CAO-NCR) on October 17, 2007. The Acting Consumer Arbitration Officer requested the Bureau of Food and Drugs (BFAD) to conduct a laboratory test on the subject product. BFAD Report of Analysis No. FCM07-10-18-151 dated October 22, 2007 confirmed the presence of live insect larvae and determined that the cream powder possessed a strong stale odor rendering it unfit for human consumption.
• Administrative Proceedings: The CAO-NCR issued a Resolution on January 11, 2016, finding that substantial evidence proved Nestle violated the Consumer Act of the Philippines (RA 7394) by distributing adulterated food. The resolution ordered Nestle to pay an administrative fine of P20,000.00, provide assurance of compliance, restitute Jarra with two bottles of RC Cola or reimburse their value, pay P5,000.00 in expenses, and condemned the subject product. Nestle's motion for reconsideration was denied on June 8, 2016.
• Appeal to DOH Secretary: Nestle appealed to the Office of the Secretary of Health, which issued a Decision on April 17, 2017 affirming the CAO-NCR resolution with modification—deleting the P5,000.00 award for expenses and rephrasing the restitution order. The Secretary held that in the absence of clear proof of grave abuse of discretion, the BFAD findings must be upheld given the agency's technical expertise and the paramount importance of consumer welfare.
• Certiorari Proceedings in the Court of Appeals: Nestle filed a Petition for Certiorari under Rule 65 with the Court of Appeals, alleging grave abuse of discretion by the DOH. In its Decision dated October 19, 2018, the CA reversed the DOH, holding that the BFAD report failed to establish whether the adulteration occurred while the product was in Nestle's custody or during transit, storage, or handling by the vendor or consumer. The CA concluded that the infestation could have been caused by factors unrelated to Nestle's manufacturing process. The CA denied Nestle's motion for reconsideration on January 17, 2019, prompting the DOH to file the present petition.

• Scope of Judicial Review: The DOH maintained that the CA erred in reversing the administrative findings based on mere errors of judgment rather than grave abuse of discretion amounting to lack or excess of jurisdiction, which is the sole ground for certiorari under Rule 65. The DOH argued that the CA failed to find any defect in jurisdiction or arbitrariness in the DOH's decision warranting the extraordinary writ.
• Substantial Evidence Standard: The DOH asserted that the CAO-NCR and the DOH Secretary correctly applied the substantial evidence standard in finding Nestle liable under RA 7394, relying on the BFAD laboratory report and the consumer's complaint. The DOH emphasized that administrative agencies possess technical expertise warranting judicial deference to their factual findings when supported by substantial evidence.

• Arbitrary Administrative Findings: Nestle countered that courts are not bound by administrative findings of fact when there is no evidence supporting them or when the agency acted arbitrarily or with grave abuse of discretion. Nestle argued that the BFAD report merely confirmed contamination but failed to establish that the adulteration occurred during manufacture or while in Nestle's custody, as opposed to during transit, storage, or handling by the retail vendor or consumer.
• Lack of Causation: Nestle maintained that the absence of other similar complaints during the same period indicated that the infestation was not caused by defective manufacturing processes but by unknown factors occurring after the product left Nestle's control, rendering the administrative conclusion arbitrary and unsupported by substantial evidence.

• Grave Abuse of Discretion: Whether the CA properly ruled that the DOH committed grave abuse of discretion amounting to lack or excess of jurisdiction in affirming the CAO-NCR's finding of liability against Nestle.
• Substantial Evidence: Whether the CAO-NCR and the DOH properly found Nestle liable for violation of RA 7394 on the distribution of adulterated products on the basis of substantial evidence.

• Grave Abuse of Discretion: The CA improperly exercised its supervisory jurisdiction under Rule 65 by reviewing the intrinsic correctness of the DOH's evaluation of evidence rather than limiting its inquiry to whether the DOH acted with grave abuse of discretion. A petition for certiorari may only issue to correct errors of jurisdiction or when there is grave abuse of discretion characterized by an indifferent disregard for the law, arbitrariness, caprice, omission to weigh pertinent considerations, or a decision arrived at without rational deliberation—not to correct errors of judgment or factual findings. Because the CA dwelt on errors of judgment by reevaluating the BFAD report and substituting its own factual conclusions, it exceeded the limited scope of certiorari.
• Substantial Evidence: The DOH did not commit grave abuse of discretion in affirming the CAO-NCR's finding that Nestle violated Article 23(3) and Article 40(a) of RA 7394. Substantial evidence—defined as more than a mere scintilla but such relevant evidence as a reasonable mind might accept as adequate to support a conclusion—supported the administrative finding that the milk product was adulterated. The BFAD report confirming live larvae and stale odor, combined with Jarra's complaint, constituted sufficient basis for liability. Under the doctrine of conclusiveness of administrative findings of fact, courts accord great weight and respect to findings of administrative bodies supported by substantial evidence, particularly where the agency possesses technical expertise, as the BFAD does in food safety matters. Nestle failed to overcome this presumption, offering only denials and self-serving postulations regarding alternative causes of infestation without sufficient proof.

• Scope of Certiorari under Rule 65 — The writ of certiorari is limited to keeping lower courts or quasi-judicial bodies within their jurisdiction and cannot be issued for any other purpose. It is confined to correcting errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction, not errors of judgment or the intrinsic correctness of factual findings. Grave abuse of discretion involves a defect of jurisdiction brought about by an indifferent disregard for the law, arbitrariness and caprice, an omission to weigh pertinent considerations, or a decision arrived at without rational deliberation.
• Conclusiveness of Administrative Findings of Fact — Courts accord great weight and respect, if not finality and conclusiveness, to findings of fact of administrative bodies when such are supported by substantial evidence. Administrative bodies are deemed specialists in their respective fields and can resolve cases with greater expertise and dispatch than courts. Simply put, findings of fact of an administrative body are binding on courts if duly supported by substantial evidence.
• Substantial Evidence — Defined as more than a mere scintilla, substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. This standard suffices to hold one administratively liable and does not require the degree of proof necessary in criminal prosecutions.

• "The supervisory jurisdiction of a court over the issuance of a writ of certiorari cannot be exercised for the purpose of reviewing the intrinsic correctness of a judgment of the lower court - on the basis either of the law or the facts of the case, or of the wisdom or legal soundness of the decision. Even if the findings of the court are incorrect, as long as it has jurisdiction over the case, such correction is normally beyond the province of certiorari."
• "A writ of certiorari's main function is limited to keeping the lower courts or quasi-judicial bodies within their jurisdiction, thus, it cannot be issued for any other purpose."
• "Under the doctrine of conclusiveness of administrative findings of fact, the courts accord great weight and respect, if not finality and conclusiveness, to findings of fact of administrative bodies when such are supported by substantial evidence."
• "Substantial evidence is more than a mere scintilla but is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion, would suffice to hold one administratively liable."

• Spouses Leynes v. Court of Appeals, 655 Phil. 25 (2011) — Cited for the principle that certiorari does not permit review of the intrinsic correctness of a judgment but is limited to jurisdictional errors.
• Bugaoisan v. OWI Group Manila, G.R. No. 226208, February 7, 2018 — Cited for the limited function of certiorari in keeping tribunals within jurisdiction.
• Montoya v. Trammed Manila Corporation, 613 Phil. 696 (2009) — Cited regarding the scope of review in petitions involving grave abuse of discretion by quasi-judicial bodies.
• Miro v. Mendoza, 721 Phil. 772 (2013) and Galindez v. Firmalan, G.R. No. 187186, June 6, 2018 — Cited for the doctrine of conclusiveness of administrative findings of fact.
• Lim v. Fuentes, G.R. No. 223210, November 6, 2017 — Cited for the definition of substantial evidence in administrative proceedings.

• Rule 65, Section 1, Rules of Court — Governs petitions for certiorari, limiting the remedy to cases where a tribunal has acted without or in excess of jurisdiction or with grave abuse of discretion amounting to lack or excess of jurisdiction.
• Rule 45, Rules of Court — Governs petitions for review on certiorari, limited to questions of law.
• Article 23(3), Republic Act No. 7394 (Consumer Act of the Philippines) — Defines adulterated food as including food that consists in whole or in part of any filthy, putrid or decomposed substance, or is otherwise unfit for food.
• Article 40(a), Republic Act No. 7394 (Consumer Act of the Philippines) — Prohibits the manufacture, importation, exportation, sale, offering for sale, distribution or transfer of any food that is adulterated or mislabeled.

Perlas-Bernabe, S.A.J. (Chairperson), Hernando, and Inting, JJ.