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VOL. 1, JANUARY 23, 1961 27


Ormoc Sugar Co., Inc. vs. OSCO Workers Fraternity Labor
Union

ANNOTATION

FACTUAL FINDINGS OF THE COURT OF


INDUSTRIAL RELATIONS

1. Requirement as to factual findings.The Court of


Industrial Relations is not required under the statute to
make findings of fact in its decisions and it should state
clearly and distinctly the facts and the law on which its
decision is based (Ysmael & Co. vs. Court of Industrial
Relations, L14280, May 30, 1960.) In another case, the
making of specific findings has been regarded as part of the
duty of the Industrial Court to "render its decisions in such
a manner the parties to the proceedings can know the
various issues involved" (Ang Tibay vs. Court of Industrial
Relations, 69 Phil. 635.)
2. Conclusiveness.Gtenerally, the factual findings of
the Industrial Court are final and conclusive on the
Supreme Court, unless it acts with grave abuse of
discretion, or such findings have absolutely no support in
the evidence on record or are unsupported by substantial
evidence (Madrigal Shipping Co. vs. Del Rosario, L13190,
Oct. 31, 1959 National Labor Union vs. Sta. Ana, 102 Phil.
302 Philippine Air Lines vs. PAL Employees Association,
104 Phil. 1058 Donato vs. Phil. Marine Officers'
Association, L12506, May 18, 1959 National Labor Union
vs. Dinglasan, 98 Phil. 649 Insurefco Paper PuLp & Project
Workers Union vs. Insular Sugar Refining Corporation, 95
Phil. 761 G.P.T.C. Employees Union vs. Court of Industrial
Relations, 102 Phil. 538 Manila Trading & Supply Co. vs.
Manila Trading Laborers' Association, 83 Phil. 297.) In
unfair labor practice cases, the Industrial Peace Act is
explicit that such findings be conclusive if supported by
substantial evidence (Sec. 6, Rep. Act No. 875.)
Thus, the appellate jurisdiction of the Supreme Court
appears to be limited to "any case involving a question of
law" (Sec. 15, Com. Act No. 103). In unfair labor practice
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cases, it is expressly provided that "appeal to the Supreme


Court shall be limited to questions of law only"

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Ormoc Sugar Co., Inc. vs. OSCO Workers Fraternity Labor
Union

(Sec. 6, Rep. Act No. 875). Note that while only "questions
of law" may be raised in the appeal or petition for certiorari
under the old Rules of Court (Sec. 2, Rule 44), the Revised
Rules of Court allow a petition for certiorari on a "question
of substance" (Sec. 5, Rule 43).
It is not for the Supreme Court to review the findings of
fact of the Court of Industrial Relations in the absence of
grave abuse of discretion amounting to lack or excess of
jurisdiction. As long as there is evidence to support a
decision or order of the Industrial Court, the Supreme
Court should not interfere, modify or reverse it (Philippine
Newspapers' Guild vs. Evening News, Inc.., 86 Phi.1. 303
Ongsiako vs. Gamboa, 86 Phil. 50 G.P.T.C. Employees
Union vs. Court of Industrial RelaHons, supra Dee C.
Chuan & Sons vs. Nahag, 95 Phil. 837 Marcelo Rubber &
Latex Products, Inc. vs. Court of Industrial Relations, 93
Phil. 1024 Sunripe Coconut Products Co. vs. Court of
Industrial Relations, 83 Phil. 518). Thus, the Supreme
Court has refused to review the conclusions of the Indus
trial Court, involving questions of fact where sufficient
evidence supports such conclusions. (Meralco Workers
Union vs. Manila Electric Company, L11876, May 29,
1959 Philippine Air Lines vs. PAL Employees Assn., 104
Phil. 1058 Philippine Sugar Institute us. Court of
Industrial Relations, L13464, May 23, 1960 Philippine
Refining Co. Workers Union vs. Philippine Refining
Company, 80 Phil. 531 Kaisahan ng mga Manggagawa sa
Kahoy sa Pilipinas vs. Gotamco Sawmill, 80 Phil. 521
Association of Drugstore Employees vs. Martinez, 102 Phil.
561 Gonzalo Puyat Timber Concession Employees Union
vs. Court of Industrial Relations, 102 Phil. 538: Indias vs.
Phil. Iron Mines, 101 Phil. 297 15 Cents & Up Employees
Association vs. Department Store and Bazaar Free Workers
Union, 100 Phil. 1083 Scoty's Dept. Store vs. Micaller, 99
Phil. 762 Operators. Inc. vs. Pelagio, 99 Phil. 893 AtokBig
Wedge Mining Co., Inc. vs. AtokBig Wedge Mutual Benefit
Association, 93 Phil. 62 Western Mindanao Lumber Co. vs.
Mindanao FederatAon of Labor, 101 Phil. 200 Dee C.
Chuan & Sons, Inc. vs. Nahag, 95 Phil. 837 Insurefco
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Employees Union vs. Insular Sugar Refining Company, 93


Phil. 761 National Organization of Laborers &

29

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Ormoc Sugar Co., Inc. vs. OSCO Workers Fraternity Labor
Union

Employees vs. Roldan, 95 Phil. 727 Philippine


Manufacturing Company vs. National Labor Union, 85
Phil. 298 Bachrach Motors Co. vs. Rural Transit
Employees Association, 85 Phil. 252.)
The following matters have been held to be findings of
fact: (1) that the employees worked for more than eight
hours a day (Isaac Peral Bowling Alley vs. United
Employees Welfare Association, 102 Phil. 219) (2) that the
laborer was dismissed without cause (Western Mindanao
Lumber Co. vs. Mindanao Federation of Labor, 101 Phil.
200) (3) that the cause of dismissal was dishonesty and not
union activity (National Labor Union vs. Standard
Vacuum Oil Co., 73 Phil. 279) (4) that the intention of the
employer was to discriminate against the dismissed
employees for being union members (Manila Electric
Company vs. National Labor Union, 70 Phil. 617) (5) that
the relation was one of employment, not of independent
contractorship (Sunripe Coconut Products Co. vs. Court of
Industrial Relations, 83 Phil. 520) (6) that the employer
was not, operating a business or industrial enterprise but a
nonprofit club for the exclusive benefit of its members
(Elks Club vs. United Laborers & Employees of Elks Club,
L9747, Feb. 27, 1959) (7) that dismissal was not for
reason of union activities (Lakas ng Pagkakaisa sa Peter
Paul vs. Court of Industrial Relations, 102 Phil. 1059) (8)
that the employee was not guilty of negligence as charged
by the employer (Destileria Ayala vs. Liga Nacional Obrera
de Filipinas, 74 Phil. 232) (9) that the employees were not
dismissed for lack of work (Bardwill Bros. vs. Phil. Labor
Union, 68 Phil. 436) (10) that the alleged breach of trust
was not supported by evidence (AtokBig Wedge Mining Co.
vs. AtokBig Wedge Mutual Benefit Association, supra) (11)
that the alleged voter in the certification election was not
in the list of eligible voters and that the list was final (15
Cents & Up Employees Association vs. Department Store &
Bazaar Free Workers Union, supra) and (12) that the
company provoked the strike by imposing oppressive
regulations (Rex Taxicab vs. Court of Industrial Relations,
70 PhiL 621).
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3. Quantum of evidence.Findings of fact by the CIR are


final and conclusive, but these must be supported by

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30 SUPREME COURT REPORTS ANNOTATED


Ormoc Sugar Co., Inc. vs. OSCO Workers Fraternity Labor
Union

some evidence. (Insurefco Employees Union vs. Insular


Sugar Refining Company, supra Philippine Newspapers'
Guild vs. Evening News, Inc., supra Antamok Goldfields
Mining Co. vs. Court of Industrial Relations, 70 Phil. 341
Dec C. Chuan & Sons, Inc. vs. Nahag, supra Sunripe
Coconut Products Co. vs. Court of Industrial Relations,
supra.) This evidence must be substantial. (Ang Tibay vs.
Court of lndv.Miri.al Relations, supra.) Findings which are
not supported by substantial evidence are not binding on
the reviewing court. (Union of the Philippine Education
Employees (NLU) vs. Philippine Education Company, 91
Phil. 93). The requirement that finding's of fact must be
supported by substantial evidence constitutes one of the
cardinal principles of procedural due process. (Ang Tibay
vs. Court of Industrial Relations, supra.) It is not necessary
that such evidence be preponderant or overwhelming the
requirement is satisfied if the evidence is credible or
rational. (Insurefco Employees Union vs. Insular Sugar
Refining Company, supra Philippine Newspapers' Guild
vs. Evening News, Inc., supra.) Preponderance of evidence
is not the issue the findings of fact stand if supported by
substantial or credible evidence. (National Fastener
Corporation vs. Court of Industrial Relations, L15834, Jan.
20, 1961). Thus, the existence of proof which mililates
against the findings of fact does not necessarily warrant
reversal. (National Fastener Corporation vs. Court of
Industrial Relations, supra Philippine Newspapers' Guild
vs. Evening News, Inc., supra,.)
In unfair labor practice cases, the substantial evidence
rule is explicitly required. The Industrial Peace Act
provides that "the findings of the Court if supported by
substantial evidence shall be conclusive". (Sec. 6, Rep. Act
No. 875.) Thus, decisions of the Supreme Court involving
questions of fact largely concern the issue whether the
conclusions of the Court of Industrial Relations are
supported by the evidence of record. (National Fastener
Corporation vs. Court of Industrial Relations, supra.)
Where substantial evidence is found, the conclusions are
not disturbed. (Permanent Concrete Products vs. Frivaldo,
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L14179, Sept. 15, 1960 Compaia Maritima vs. United


Seamen's Union, 104 Phil. 7 Donato vs. Philippine Marine
31

VOL. 1, JANUARY 28, 1961 31


In re Dianala Jo

Officers Association, supra). Where such findings are not


supported by substantial evidence, they may be set aside
(Management of El Hogar Filipino Mutual Bldg. & Loan
Association vs. Building Employees Association, L9740,
March 30, 1960 Royal Interocean Lines vs. Court of
Industrial Relations, L11745, Oct. 31, 1960 Isaac Peral
Bowling Alleys vs. United Employees Welfare Association,
L15439, Nov. 29, 1960 Operators, Inc. vs. National Labor
Union, L15073, May 26 1960).
4. What is substantial evidence.Substantial evidence
has been defined as such relevant evidence as a reasonable
mind might accept as adequate to support a conclusion.
(Ang Tibay vs. Court of Industrial Relations, supra). It
means such evidence which affords a substantial basis from
which the fact in issue can be reasonably inferred (U.S.
Lines vs. Associated Watchmen & Security Union, L 12218,
May 21, 1958).

Notes.In the Ormoc Sugar Company case, the finding


of the Industrial Court on the dismissal of an employee was
reversed by the Supreme Court. However, generally, the
Supreme Court is bound by the findings of the Industrial
Court, which are supported by substantial evidence, that
the employer dismissed the employee for just causes, such
as drunkenness, dishonesty, negligence, etc. (Cinema,
Stage & Radio Entertainment Free Workers' vs. Court of
Industrial Relations, L19879, Dec. 17, 1966, 18 Supreme
Court Reports Annotated 1068). As, to the finality of the
findings of the Industrial Court, see annotation under East
Asiatic Co., Ltd. vs. Court of Industrial Relations, L17037,
April 30, 1966, 16 Supreme Court Reports Annotated 820.

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