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JULIO B. PURCON v. MRM PHILIPPINES

FACTS:

Julio Purcon filed a complaint for reimbursement of medical expenses, sickness allowance, and permanent disability benefits against MRM Philippines, Inc. before the Arbitration Branch of the National Labor Relations Commission (NLRC). Purcon alleged that he was hired as a seaman on January 28, 2002, but was repatriated on June 26, 2002, due to a diagnosed hernia. He claimed that upon his return to the Philippines, he was declared fit to resume work but was not re-hired by the company because there was no vacancy for him. The Labor Arbiter dismissed Purcon's complaint for lack of merit, stating that he was fit to work and not suffering from disability. The NLRC affirmed the decision, and the Court of Appeals dismissed Purcon's petition for certiorari due to formal infirmities. Purcon filed a petition for review before the Supreme Court, which was denied and an Entry of Judgment was issued. Purcon subsequently filed a petition for relief from judgment, alleging that there were gross mistakes committed by the Labor Arbiter and NLRC in their decisions.

ISSUES:

  1. Whether the petitioner sufficiently showed that the lower courts committed reversible error in their decisions.

RULING:

  1. The Supreme Court found that the petitioner failed to convince the Court why the decisions of the Labor Arbiter, the NLRC, and the Court of Appeals should be reversed. The Court held that the petitioner did not sufficiently show any reversible error committed by the lower courts.

PRINCIPLES:

  • Relief from judgment under Rule 38 of the 1997 Rules of Civil Procedure is an equitable remedy that is allowed only in exceptional cases when there is no other available or adequate remedy. It may be availed of only after a judgment, final order, or other proceeding was taken against the petitioner in any court through fraud, accident, mistake, or excusable negligence.

  • The petitioner must sufficiently show that the negligence and inefficiency of his counsel constitute excusable negligence to be entitled to relief from judgment.

  • The petitioner must sufficiently show reversible error committed by the lower courts to warrant the exercise of the Supreme Court's discretionary appellate jurisdiction.