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Almagro vs. Philippine Airlines, Inc.

12th September 2018

ak198834
880 SCRA 107 , G.R. No. 204803
Primary Holding
The doctrines of conclusiveness of judgment and stare decisis bar the relitigation of the issue of who participated in the illegal 1998 PAL strike, as prior final Supreme Court decisions have already established that the act of signing the company's return-to-work logbook after the prescribed deadline is conclusive evidence of participation in the said strike and defiance of the return-to-work order.
Background
The case originated from a major labor dispute in the 1990s between Philippine Airlines, Inc. (PAL) and the Airline Pilots Association of the Philippines (ALPAP), the exclusive bargaining agent for PAL's commercial pilots. In response to alleged unfair labor practices by PAL, ALPAP staged a strike in June 1998, which was later declared illegal by the Secretary of Labor and Employment after the union defied a return-to-work order, leading to the mass termination of participating pilots.
Civil Procedure II

Herarc Realty Corporation vs. Provincial Treasurer of Batangas

5th September 2018

ak138657
879 SCRA 317 , G.R. No. 210736
Primary Holding
Decisions of the Regional Trial Court in local tax cases must be appealed to the Court of Tax Appeals (CTA), not directly to the Supreme Court. Substantively, the personal liability for real property tax is generally imposed on the registered owner of the property at the time the tax accrues, especially when the owner is a taxable entity.
Background
Herarc Corporation acquired thirteen parcels of land in Batangas through an execution sale in 2004 and became the registered owner in 2006. However, from March 2006 to August 2009, the property remained in the actual possession of private respondents, who were assignees in a separate involuntary insolvency case involving the previous owners. Herarc only gained full possession and control of the property on August 13, 2009, after a court-issued writ of execution. The dispute arose when the Provincial Treasurer of Batangas assessed Herarc for the unpaid real property taxes corresponding to the period when it was the registered owner but not the possessor.
Civil Procedure II

Chua vs. Commission on Elections

14th August 2018

ak973642
877 SCRA 222 , G.R. No. 236573
Primary Holding
A petition for certiorari under Rule 64 of the Rules of Court questioning a resolution of the COMELEC En Banc must be filed within the 30-day reglementary period, and the filing of a prohibited pleading, such as a second motion for reconsideration disguised as another motion, does not toll the running of this period, leading to the finality of the assailed resolution by operation of law.
Background
The case originated from an election protest concerning the results of the October 28, 2013 Barangay Elections for the position of Punong Barangay of Addition Hills, San Juan City. Petitioner Herbert O. Chua was initially proclaimed the winner with 465 votes, a five-vote lead over respondent Sophia Patricia K. Gil, who garnered 460 votes. Gil subsequently filed an election protest alleging fraud and illegal acts.
Civil Procedure II
Rule 64

Laya, Jr. vs. Philippine Veterans Bank

10th January 2018

ak558145
850 SCRA 315 , G.R. No. 205813
Primary Holding
An employer's imposition of an early retirement age (below the 65-year compulsory age under the Labor Code) is only valid if the employee's consent to such a plan is explicit, voluntary, free, and uncompelled; consent cannot be inferred from a general statement of "membership" in a retirement program in an appointment letter or from automatic membership in a plan that is essentially a contract of adhesion.
Background
Alfredo F. Laya, Jr. was hired by Philippine Veterans Bank (PVB) as its Chief Legal Counsel with the rank of Vice President. The bank had an existing Retirement Plan, established years before Laya's employment, which set the normal retirement age for its members at 60. Upon reaching this age, PVB informed Laya of his retirement. Laya contested this, claiming he did not consent to be retired at an age earlier than the 65-year compulsory age provided by the Labor Code, leading him to file a case for illegal dismissal.
Civil Procedure II

Philippine National Bank vs. Gregorio

18th September 2017

ak003970
840 SCRA 37 , G.R. No. 194944
Primary Holding
The Court of Appeals' review of a National Labor Relations Commission (NLRC) decision through a special civil action for certiorari under Rule 65 is strictly limited to determining whether the NLRC committed grave abuse of discretion amounting to a lack or excess of jurisdiction, and does not extend to correcting mere errors of judgment in the appreciation of evidence.
Background
The dispute originated when a depositor of PNB's Sucat Branch inquired about a unique high-return investment product supposedly offered by branch personnel. This prompted PNB's Internal Audit Group (IAG) to conduct a credit review, which uncovered irregular loan activities allegedly orchestrated by the branch manager, Teresita Fe A. Gregorio. The investigation, supported by affidavits from other depositors, suggested Gregorio was running an unauthorized lending scheme where depositors were convinced to take out loans against their deposits, with the proceeds being re-loaned to other borrowers at a high interest rate, all under Gregorio's supervision but without any official benefit to the bank.
Civil Procedure II
Rule 45

Cortal vs. Inaki A. Larrazabal Enterprises

30th August 2017

ak665608
838 SCRA 255 , G.R. No. 199107
Primary Holding
Procedural rules may be relaxed for persuasive reasons to prevent an injustice that is not commensurate with the degree of a litigant's procedural thoughtlessness, especially when substantial rights concerning property and livelihood are at stake; an inordinate fixation on technicalities cannot defeat the need for a full, just, and equitable litigation of claims on the merits.
Background
The case originated from the implementation of the agrarian reform program under Presidential Decree No. 27. Three parcels of land owned by private respondent Inaki A. Larrazabal Enterprises were placed under the Compulsory Acquisition Scheme in 1988. Consequently, Emancipation Patents and new transfer certificates of title were issued to the petitioners, who were the farmer-beneficiaries. The dispute arose when Larrazabal Enterprises filed an action to recover the properties, alleging that it had never been paid the required just compensation, thus rendering the transfer of titles to the petitioners void.
Civil Procedure II
Rule 43

Frondozo vs. Manila Electric Company

22nd August 2017

ak780189
837 SCRA 378 , G.R. No. 178379
Primary Holding
The Supreme Court held that the NLRC did not commit grave abuse of discretion in granting MERALCO's prayer for a preliminary injunction to suspend execution proceedings due to conflicting final and executory decisions from different Court of Appeals divisions, one of which was affirmed by the Supreme Court on the merits upholding the employees' dismissal for participating in an illegal strike; the case was remanded to the NLRC for execution of the Supreme Court's prior resolutions affirming the dismissals.
Background
The dispute arose from labor unrest at MERALCO involving unfair labor practices, union busting allegations, and strikes by rank-and-file employees under MEWA in 1991, certified to the NLRC for compulsory arbitration by the DOLE Secretary, resulting in terminations of union officers and members for alleged illegal acts during the strikes, and subsequent illegal dismissal complaints amid ongoing conciliation efforts and certifications that enjoined further strikes and ordered return-to-work.
Civil Procedure II
Rule 65

Typoco, Jr. vs. People

16th August 2017

ak004152
837 SCRA 306 , G.R. No. 221857 , G.R. No. 222020
Primary Holding
The alteration of a date on a public document, such as a Purchase Order, to conceal the absence of a prior public bidding constitutes the crime of Falsification of Public Document under Article 171 of the Revised Penal Code, as it makes the document speak a falsehood regarding an essential fact.
Background
In 2005, the Provincial Government of Camarines Norte initiated a "Medical Indigency Program" to provide medicines to indigent families. The case arose from the procurement of medicines worth over P1.6 million for this program, where the transaction was completed before the legally required public bidding was held, leading to the subsequent falsification of documents to simulate compliance with procurement laws.
Civil Procedure II

Espere vs. NFD International Manning Agents, Inc.

26th July 2017

ak175263
833 SCRA 156 , G.R. No. 212098
Primary Holding
The medical assessment of a company-designated physician, who has conducted extensive and continuous monitoring and treatment of a seafarer's condition over a significant period, is given greater evidentiary weight than the contrary opinion of a seafarer's chosen physician which is based on a single consultation and is not supported by comprehensive medical tests and records.
Background
Petitioner Julio C. Espere was employed as a Bosun by respondent NFD International Manning Agents, Inc. and was declared "Fit for Sea Duty" in his Pre-Employment Medical Examination (PEME). Approximately five months into his nine-month contract aboard the vessel M.V. Kalpana Prem, he experienced dizziness, body malaise, and chills. He was diagnosed in Vancouver, Canada with "uncontrolled hypertension," declared unfit for duty, and was medically repatriated to the Philippines for further treatment and evaluation.
Civil Procedure II

Almario-Templonuevo vs. Office of the Ombudsman

28th June 2017

ak232325
828 SCRA 283 , G.R. No. 198583
Primary Holding
A decision of the Ombudsman imposing a penalty of suspension for not more than one month is final, executory, and unappealable, which justifies direct resort to a petition for certiorari under Rule 65 without the prior filing of a motion for reconsideration. Furthermore, the condonation doctrine applies to an official elected to a different public office, provided that the electorate or "body politic" is the same for both positions.
Background
Respondent Chito M. Oyardo filed an administrative complaint before the Office of the Ombudsman against petitioner Arlyn Almario-Templonuevo for an alleged violation of law committed while she was serving as a Sangguniang Bayan Member of Caramoan, Catanduanes, from 2007 to 2010. This complaint led to the Ombudsman's investigation and subsequent decision finding her liable for simple misconduct.
Civil Procedure II
Rule 65

Asiatrust Development Bank, Inc. vs. Commissioner of Internal Revenue

19th April 2017

ak311801
823 SCRA 648 , G.R. No. 201530 , G.R. Nos. 201680-81
Primary Holding
An application for a tax abatement is considered approved only upon the issuance of a termination letter by the Bureau of Internal Revenue (BIR); without such a letter, a tax assessment is not considered closed and terminated. Furthermore, an appeal of a CTA Division's decision (including an amended decision) to the CTA En Banc requires a prior and timely-filed motion for reconsideration, the absence of which is a fatal procedural defect that warrants dismissal of the appeal.
Background
The Commissioner of Internal Revenue assessed Asiatrust for deficiency internal revenue taxes for the fiscal years 1996, 1997, and 1998. Asiatrust protested the assessments, and upon the CIR's inaction, elevated the matter to the Court of Tax Appeals. During the proceedings, Asiatrust claimed it had settled its liabilities by availing of various government tax relief programs, including a compromise on certain taxes, a tax abatement program for its deficiency final withholding tax, and the 2007 Tax Amnesty Law for its deficiency documentary stamp tax. The core dispute centered on whether Asiatrust had sufficiently proven its availment of these programs to extinguish the assessed tax liabilities.
Civil Procedure II

E. Ganzon, Inc. (EGI) vs. Ando, Jr.

20th February 2017

ak204746
818 SCRA 165 , G.R. No. 214183
Primary Holding
An employee in the construction industry hired on a project-to-project basis is considered a project employee, and the repeated and successive rehiring of such an employee does not, by itself, confer regular employment status; the validity of the project employment is not impaired by a contractual provision allowing for the extension or shortening of the employment period, as long as the termination remains tied to the completion of the specific project or a phase thereof.
Background
The case arose from the common employment practice in the construction industry where workers are hired for specific projects. E. Ganzon, Inc. (EGI), a construction company, engaged the services of Fortunato B. Ando, Jr. as a carpenter for two different construction projects under three separate project employment contracts. The dispute centered on whether Ando's repeated hiring for tasks necessary to EGI's business made him a regular employee entitled to security of tenure beyond the completion of the projects.
Civil Procedure II

Galindo vs. Commission on Audit

10th January 2017

ak489503
814 SCRA 73 , G.R. No. 210788
Primary Holding
Decisions of the Commission on Audit in administrative disciplinary cases are not reviewable by the Supreme Court through a petition for certiorari under Rule 64; the proper remedy is an appeal to the Civil Service Commission, as provided by the Administrative Code of 1987.
Background
The case arose from a long-standing practice within the Metropolitan Waterworks and Sewerage System (MWSS) of granting bonuses, allowances, and other benefits to personnel of the Commission on Audit (COA) assigned to audit it. This practice was brought to the attention of the COA Chairman through a letter from the MWSS Administrator, which detailed how unrecorded checks were being issued from cash advances to pay these benefits, bypassing usual accounting procedures. This prompted the COA to form a fact-finding investigation team, which ultimately led to the filing of administrative charges against the petitioners and other COA personnel involved.
Civil Procedure II

Nicolas vs. Agrarian Reform Beneficiaries Association (ARBA)

19th October 2016

ak689125
806 SCRA 453 , G.R. No. 179566
Primary Holding
The Supreme Court held that procedural rules should be relaxed to avoid injustice where lapses are excusable and merits demand review; the execution pending appeal by petitioners violated DARAB Rules requiring a motion and good reasons, rendering subsequent title acts void, but the DARAB decision must be annulled to conform with the final Supreme Court ruling in the related case exempting the land from CARP coverage; petitioners are liable for nominal damages, attorney's fees, and costs for violating respondents' due process rights through bad faith execution.
Background
The dispute arises from the erroneous inclusion of two urban-zoned parcels of land in Davao City under the Comprehensive Agrarian Reform Program (CARP) in 1994, leading to their cancellation and award via CLOA to agrarian reform beneficiaries; petitioners acquired the lands from Philippine Banking Corporation via deed of assignment and sought cancellation of the CLOA, claiming exemption as non-agricultural land, which triggered multiple proceedings challenging the validity of title transfers and executions pending appeal in the agrarian reform adjudication system.
Civil Procedure II

Escoto vs. Philippine Amusement and Gaming Corporation

17th October 2016

ak896965
806 SCRA 116 , G.R. No. 192679
Primary Holding
An appeal from a decision of a Regional Trial Court rendered in the exercise of its original jurisdiction that raises only pure questions of law must be filed directly with the Supreme Court through a petition for review on certiorari under Rule 45 of the Rules of Court; an erroneous appeal to the Court of Appeals on such grounds is not subject to transfer and must be dismissed outright.
Background
The petitioner, Antonio Escoto, and the late Edgar Laxamana were promoters for Legend International Resort Limited (LIRL) located within the Subic Bay Freeport Zone. As part of their promotional activities, they organized a tourist-oriented cockfighting derby and secured a permit from the Subic Bay Metropolitan Authority (SBMA). The Philippine Amusement and Gaming Corporation (PAGCOR) intervened, advising LIRL to cancel the event on the grounds that cockfighting was outside its competence as a hotel casino resort, which led to the legal dispute.
Civil Procedure II
Rule 45

Fuji Television Network, Inc. vs. Espiritu

3rd December 2014

ak058947
744 SCRA 31 , G.R. Nos. 204944-45
Primary Holding
An employer has the burden to prove that a person it pays for services is an independent contractor; otherwise, the person is presumed to be a regular employee. Termination of an employee due to disease is only valid if a competent public health authority certifies that the disease is incurable within six months and that continued employment is prejudicial to health, and such termination must comply with due process.
Background
In 2005, Fuji Television Network, Inc. engaged Arlene S. Espiritu as a news correspondent/producer for its Manila Bureau. Her employment was governed by a one-year fixed-term contract that was renewed annually for four years. In January 2009, Arlene was diagnosed with lung cancer and informed Fuji of her condition. Subsequently, Fuji's management told her that they would have a problem renewing her contract due to her illness, despite her insistence that she was still fit to work. This led to a dispute over the nature of her employment and the legality of the non-renewal of her contract.
Civil Procedure II

Lihaylihay vs. People

31st July 2013

ak161655
702 SCRA 755 , G.R. No. 191219
Primary Holding
Public officers who certify and approve documents for non-existent purchases through evident bad faith, despite glaring irregularities such as tampered dates and incomplete certifications, commit a violation of Section 3(e) of RA 3019, resulting in undue injury to the government; the Arias doctrine does not apply where circumstances demand higher circumspection from approving officers.
Background
The case arose from a Commission on Audit special audit report revealing irregularities in PNP procurement, prompting an internal PNP investigation into alleged "ghost" purchases of combat, clothing, and individual equipment (CCIE) worth P133,000,000 from the PNP Service Store System to the PNP General Services Command, leading to charges against multiple PNP officers for corrupt practices under RA 3019.
Civil Procedure II

Reblora vs. Armed Forces of the Philippines

18th June 2013

ak765347
698 SCRA 727 , G.R. No. 195842
Primary Holding
Decisions of the Commission on Audit (COA) are reviewable by the Supreme Court not through an appeal by certiorari under Rule 45, but through a special civil action for certiorari under Rule 64, which limits the scope of review to errors of jurisdiction or grave abuse of discretion. Furthermore, under Presidential Decree No. 1638, prior civilian government service is included in the computation of a military officer's "active service," which can trigger the conditions for compulsory retirement (attaining 56 years of age or 30 years of active service, whichever is later) at an earlier date.
Background
The petitioner, a retired military officer, had rendered service as a civilian employee in the Department of the Interior and Local Government (DILG) before joining the Philippine Navy. Upon his retirement, a dispute arose regarding the computation of his retirement benefits. The AFP calculated his benefits based only on his actual military service, excluding his prior civilian service. The petitioner contested this, believing his civilian service should be added to his military service for a higher benefit, leading him to seek redress from the Commission on Audit.
Civil Procedure II
Rule 45

Royal Plant Workers Union vs. Coca-Cola Bottlers Philippines, Inc.-Cebu Plant

15th April 2013

ak849198
696 SCRA 357 , G.R. No. 198783
Primary Holding
The removal of chairs for bottling operators is a valid exercise of management prerogative when done in good faith to improve business efficiency and safety, especially when compensated by other measures like adjusted work schedules; the long-term provision of such chairs does not ripen into a vested right or a benefit protected under the non-diminution rule of Article 100 of the Labor Code, which applies to monetary benefits or privileges with monetary equivalents.
Background
For over three decades, Coca-Cola Bottlers Philippines, Inc. (CCBPI) provided chairs for its bottling operators at its Cebu plant. In September 2008, pursuant to a national directive aligned with its "I Operate, I Maintain, I Clean" program, CCBPI removed these chairs. The company reasoned that the operators' tasks required constant movement and that removing the chairs would enhance efficiency and prevent operators from sleeping on the job, thereby reducing the risk of accidents. This unilateral decision by management prompted the Royal Plant Workers Union (ROPWU) to initiate a grievance, which eventually led to the legal dispute.
Civil Procedure II

Callo-Claridad vs. Esteban

20th March 2013

ak496970
694 SCRA 185 , G.R. No. 191567
Primary Holding
The determination of probable cause for filing a criminal information is an executive function exclusively within the competence of the Secretary of Justice, and courts cannot interfere absent a clear showing of grave abuse of discretion amounting to lack or excess of jurisdiction; in this case, no such abuse occurred as the circumstantial evidence was incompetent and insufficient to establish probable cause for charging the respondents with murder.
Background
The case arises from the unsolved stabbing death of 17-year-old Chase Callo Claridad on February 27, 2007, in the carport of an uninhabited house in Ferndale Homes, Quezon City, amid suspicions of involvement by respondent Philip Esteban, a friend of the victim, and his mother Teodora, fueled by observations of their vehicles at the scene, prior parking disputes in the subdivision, and the family's subsequent non-cooperation with investigators, though no direct evidence or motive linked them to the crime.
Civil Procedure II

Tan, Jr. vs. Matsuura

9th January 2013

ak725361
688 SCRA 263 , G.R. No. 179003 , G.R. No. 195816
Primary Holding
The Court of Appeals correctly exercised its power to review the Department of Justice's findings for grave abuse of discretion, and there was no probable cause to indict the respondents for falsification under Articles 171 and 172 of the Revised Penal Code, as the elements of the crime, including alteration changing the document's meaning and damage, were not sufficiently established during the preliminary investigation.
Background
The case arose from an intra-corporate dispute in TF Ventures, Inc., involving Tan and Matsuura, where Tan accused Matsuura and others of stealing company properties, including a pre-signed blank Deed of Trust; this led to a qualified theft case against Matsuura and associates, and Tan later claimed the deed was filled and notarized without his consent as part of a compromise attempt, prompting falsification charges amid ongoing hostilities and legal battles before the Securities and Exchange Commission.
Civil Procedure II

Belongilot vs. Cua

24th November 2010

ak244573
636 SCRA 34 , G.R. No. 160933
Primary Holding
The Supreme Court held that the Ombudsman committed grave abuse of discretion by dismissing the complaint without properly assessing probable cause for violation of Section 3(e) of R.A. No. 3019, as the DARAB respondents' issuance of a TRO and injunction after the final and executed PARAD decision evidenced manifest partiality, evident bad faith, or gross inexcusable negligence, warranting the filing of criminal charges.
Background
The dispute arose from a long-standing agrarian reform case involving parcels of land in Bulacan owned by the petitioner's wife, which were forcibly occupied and converted into a fishpond by Juanito Constantino in 1979, leading to an ejectment suit under the Department of Agrarian Reform framework and subsequent procedural maneuvers that culminated in the petitioner's loss of possession despite a favorable final decision.
Civil Procedure II
Rule 45 vs Rule 65

Mitra vs. Commission on Elections

19th October 2010

ak877231
633 SCRA 580 , G.R. No. 191938
Primary Holding
The Supreme Court is constitutionally bound to exercise its certiorari jurisdiction to review and correct actions of the COMELEC when the latter commits grave abuse of discretion, such as when its appreciation of evidence is grossly unreasonable or when it uses subjective, non-legal standards in its evaluation, thereby transforming an error of judgment into a reviewable error of jurisdiction.
Background
Abraham Kahlil Mitra, a three-term congressman whose district included Puerto Princesa City, intended to run for Governor of Palawan in the May 2010 elections. Due to the reclassification of Puerto Princesa City as a highly urbanized city, its residents became ineligible to vote for or be elected to provincial offices. To qualify for the gubernatorial race, Mitra needed to establish residence in a municipality within the province of Palawan for at least one year prior to the election. He declared Aborlan, Palawan as his new residence in his Certificate of Candidacy, which prompted private respondents to file a petition for its cancellation, alleging material misrepresentation.
Civil Procedure II
Rule 64 and 65

Salvador vs. Mapa

28th November 2007

ak471249
539 SCRA 34 , G.R. No. 135080
Primary Holding
The prescriptive period for violations of Republic Act No. 3019 in behest loan cases commences from the date of discovery by the Presidential Ad Hoc Fact-Finding Committee on Behest Loans in 1992, not from the commission of the acts, and Administrative Order No. 13 and Memorandum Order No. 61 are not ex post facto laws as they are not penal in nature.
Background
During the Marcos administration, government financial institutions granted loans at the behest of high officials to cronies, often under-collateralized and to undercapitalized entities, leading to significant losses for the government; post-1986 EDSA Revolution, efforts to recover such ill-gotten wealth prompted the creation of investigative bodies, including the Presidential Ad Hoc Fact-Finding Committee on Behest Loans under Administrative Order No. 13 in 1992 to inventory and recommend recovery actions for these loans.
Civil Procedure II
Rule 45 vs. Rule 65

Golangco vs. Fung

16th October 2006

ak531157
504 SCRA 321 , G.R. No. 147640 , G.R. No. 147762
Primary Holding
A public officer's warrantless arrest during a legitimate entrapment operation, based on reasonable belief of violation of labor laws prohibiting unauthorized recruitment activities, does not constitute administrative offenses like oppression or grave misconduct when performed in good faith, though courts lack jurisdiction to review Ombudsman findings of probable cause in criminal cases.
Background
The case arises from complaints about excessive placement fees charged by recruitment agencies for overseas employment, leading to investigations by the Philippine Overseas Employment Administration (POEA) under the Department of Labor and Employment (DOLE) to enforce labor laws against illegal recruitment practices, including non-transferability of recruitment licenses.
Civil Procedure II
Rule 43

Enemecio vs. Office of the Ombudsman (Visayas)

13th January 2004

ak712428
419 SCRA 82 , G.R. No. 146731
Primary Holding
A petition for certiorari under Rule 65 challenging the Ombudsman's dismissal of a criminal complaint must be filed directly with the Supreme Court, not the Court of Appeals, as the latter lacks jurisdiction over such matters under Republic Act No. 6770; furthermore, the Ombudsman did not commit grave abuse of discretion in dismissing the complaint for falsification of public documents, as no law requires disclosure of the specific purpose or location for using earned leave credits, and thus no untruthful narration of facts occurred under Article 171 of the Revised Penal Code.
Background
The dispute arose in the context of workplace tensions at the Cebu State College of Science and Technology, College of Fisheries Technology, where Enemecio, as a utility worker, accused Bernante, an assistant professor, of professional misconduct including defamatory acts and falsifying leave records to conceal his incarceration for slight physical injuries, amid retaliatory filings between parties involving school officials, highlighting issues of administrative accountability and the proper use of government employee leave benefits under Philippine civil service regulations.
Civil Procedure II
Rule 65

Carpio vs. Sulu Resources Development Corporation

8th August 2002

ak328564
387 SCRA 128 , G.R. No. 148267
Primary Holding
Decisions and final orders of the Mines Adjudication Board (MAB) are appealable to the Court of Appeals under Rule 43 of the 1997 Rules of Court, as the MAB is a quasi-judicial agency, and Section 79 of RA 7942, which suggests direct appeal to the Supreme Court, is modified by procedural rules and constitutional principles limiting expansions of the Supreme Court's appellate jurisdiction without its consent.
Background
The case arises from a mining dispute under the Philippine Mining Act of 1995 (RA 7942), involving conflicting claims to quarry resources in Antipolo, Rizal, where private landowners like the petitioner assert preferential rights over areas overlapping with corporate mining applications, highlighting tensions between individual property rights and administrative mining allocations by the Department of Environment and Natural Resources (DENR).
Civil Procedure II
Rule 43

St. Martin Funeral Home vs. NLRC

16th September 1998

ak033899
295 SCRA 494 , G.R. No. 130866
Primary Holding
Petitions for certiorari under Rule 65 seeking judicial review of NLRC decisions must be initially filed with the Court of Appeals, not directly with the Supreme Court, in observance of the doctrine on hierarchy of courts, as all references to "appeals" from NLRC in amended Section 9 of B.P. Blg. 129 are deemed to mean such special civil actions.
Background
The case emerges amid increasing labor disputes reaching the Supreme Court and legislative amendments to the Labor Code (P.D. No. 442) and the Judiciary Reorganization Act (B.P. Blg. 129), particularly R.A. No. 7902, which expanded the Court of Appeals' jurisdiction over quasi-judicial agencies but created ambiguity regarding review of NLRC decisions, prompting the Court to reassess the procedural mode of judicial review to alleviate its workload and ensure efficient adjudication.
Civil Procedure II
Rule 65