In Samahan ng mga Manggagawa sa Hyatt v. Voluntary Arbitrator Froilan M. Bacungan and Hyatt Regency Manila, the Supreme Court clarified that decisions made by voluntary arbitrators in labor disputes are appealable to the Court of Appeals. This ruling reinforces the importance of following the correct procedure when challenging labor decisions. The Court emphasized that filing a special civil action for certiorari is not the proper remedy; instead, a petition for review under Rule 43 of the Rules of Court should be pursued, streamlining the process for labor disputes and ensuring consistency with quasi-judicial entities.

Independent Contractors or Regular Employees? The Hyatt Labor Dispute

The case originated from a dispute between the Samahan ng mga Manggagawa sa Hyatt-NUWHRAIN-APL (petitioner union) and Hyatt Regency Manila (respondent Hyatt) regarding the employment status of several workers. The petitioner union questioned whether certain employees, namely Dacles, Valencia, Dalmacio, and Dazo, should be considered regular employees given the nature of their work and the length of their service. Hyatt maintained that Dacles and Valencia were employees of City Service Corporation (CSC), an independent contractor, while Dalmacio and Dazo were project employees tied to the flower shop’s operation. When negotiations failed, the matter was brought to voluntary arbitration, leading to a decision that prompted the union to seek recourse through a special civil action for certiorari, which the Court of Appeals dismissed as the wrong remedy.

The central legal question was whether the Court of Appeals erred in ruling that the appropriate remedy for assailing the decision of the voluntary arbitrator was a petition for review under Rule 43, rather than a petition for certiorari under Rule 65 of the Rules of Civil Procedure. The petitioner union argued that decisions of voluntary arbitrators should be treated similarly to those of the National Labor Relations Commission (NLRC) or the Secretary of Labor and Employment, which are final and executory after ten days and not subject to appeal. They also contended that Section 2 of Rule 43, which exempts judgments issued under the Labor Code, should apply to decisions of labor voluntary arbitrators.

The Supreme Court addressed the issue of the proper recourse for challenging a voluntary arbitrator’s decision. The Court referred to Luzon Development Bank v. Association of Luzon Development Bank Employees, emphasizing that decisions or awards of voluntary arbitrators are appealable to the Court of Appeals. This aligns with the procedure outlined in Rule 43 of the 1997 Rules of Civil Procedure, which is consistent with providing a uniform appellate review process for quasi-judicial entities.

The decision or award of the voluntary arbitrator or panel of arbitrators should likewise be appealable to the Court of Appeals, in line with the procedure outlines in Revised Administrative Circular No. 1-95 (now embodied in Rule 43 of the 1997 Rules of Civil Procedure), just like those of the quasi-judicial agencies, boards and commissions enumerated therein, and consistent with the original purpose to provide a uniform procedure for the appellate review of adjudications of all quasi-judicial entities.

Moreover, the Court cited Alcantara, Jr. v. Court of Appeals, and Nippon Paint Employees Union v. Court of Appeals, which reaffirmed the ruling in Luzon Development Bank. In Alcantara, the Court clarified that despite Section 2 of Rule 43, the Luzon Development Bank ruling still stands, meaning that decisions of voluntary arbitrators issued pursuant to the Labor Code are not exempt from appeal to the Court of Appeals. The Court acknowledged that, under certain circumstances, rules of procedure can be relaxed. However, in this case, the Court of Appeals correctly pointed out that the petition was filed beyond the reglementary period for filing a petition for review under Rule 43. Erroneously using a petition for certiorari does not substitute for a lost appeal.

Beyond the procedural issues, the Supreme Court affirmed the voluntary arbitrator’s findings regarding the employment status of the workers in question. The Court found no reversible error in the arbitrator’s decision that Dacles and Valencia were employees of CSC, an independent contractor. The Court emphasized that absent evidence proving that CSC was engaged in labor-only contracting, the workers could not be considered employees of respondent Hyatt. Similarly, the Court upheld the finding that Dalmacio and Dazo were project employees, whose employment could be terminated upon the closure of the flower shop, as stipulated in their employment contracts. Administrative agencies and quasi-judicial bodies are generally accorded great respect and finality regarding their factual findings, unless there is a showing of grave abuse of discretion or disregard of the evidence on record.

FAQs

What was the key issue in this case?	The key issue was whether a decision of a voluntary arbitrator in a labor dispute should be appealed through a petition for certiorari or a petition for review under Rule 43 of the Rules of Court.
What did the Supreme Court rule regarding the appeal process?	The Supreme Court ruled that decisions of voluntary arbitrators are appealable to the Court of Appeals via a petition for review under Rule 43, not through a special civil action for certiorari.
Who were Dacles and Valencia considered employees of?	Dacles and Valencia were considered employees of City Service Corporation (CSC), an independent contractor, and not of Hyatt Regency Manila.
Why were Dacles and Valencia not considered regular employees of Hyatt?	They were not considered regular employees of Hyatt because they were employed by CSC, and there was no evidence that CSC was engaged in labor-only contracting.
What was the employment status of Dalmacio and Dazo?	Dalmacio and Dazo were considered project employees whose employment was tied to the operation of the flower shop at Hyatt Regency Manila.
What happens to Dalmacio and Dazo if the flower shop closes?	Their employment could be terminated upon the closure of the flower shop, according to the terms of their employment contracts.
What is the general rule regarding findings of administrative agencies?	Findings of fact by administrative agencies and quasi-judicial bodies are generally accorded great respect and finality, unless there is a showing of grave abuse of discretion or disregard of evidence.
What was the outcome of the petition in this case?	The Supreme Court denied the petition and affirmed the resolutions of the Court of Appeals, reinforcing the proper procedure for appealing voluntary arbitration decisions.

This case underscores the importance of adhering to procedural rules when seeking judicial review of labor decisions. Understanding the proper avenue for appeal, whether through a petition for review or a special civil action, can significantly impact the outcome of a labor dispute. Following the correct procedure ensures that grievances are heard and resolved in a timely and efficient manner.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: SAMAHAN NG MGA MANGGAGAWA SA HYATT vs. BACUNGAN, G.R. No. 149050, March 25, 2009