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DEPARTMENT OF HEALTH v. NESTLE PHILIPPINES

FACTS:

This case involves a petition for review on certiorari filed by Nestle Philippines, Inc. (Nestle) against the Decision and Resolution of the Court of Appeals (CA) in favor of Mymanette M. Jarra (Jarra). Jarra purchased a Nestle Bear Brand Powdered Filled Milk from a store, but found larvae and noticed that the powder was yellowish and lumpy upon opening the pack. She filed a complaint with the DOH Consumer Arbitration Office (CAO-NCR) and the Bureau of Food and Drugs (BFAD) conducted a laboratory test on the product. The BFAD confirmed the presence of live insect larvae and declared the powder unfit for human consumption.

The CAO-NCR issued a Resolution in favor of Jarra, finding a violation of the Consumer Act of the Philippines. This Resolution ordered Nestle to pay a fine, comply with the provisions of the Act, restitute Jarra with RC Cola or its value, and pay Jarra's expenses in pursuing the complaint. Nestle filed a motion for reconsideration, which was denied, leading to an appeal before the DOH. The Secretary of Health affirmed the CAO-NCR Resolution with modification, deleting the award of expenses to Jarra. Nestle's motion for reconsideration was also denied by the Secretary of Health.

Nestle then filed a Petition for Certiorari before the CA, which ruled in favor of Nestle, reversing the DOH's Decision and Resolution. The DOH elevated the case to the Supreme Court via a Petition for Review on Certiorari. The DOH argues that there was no grave abuse of discretion on its part and that there was substantial evidence to support the violation of the Consumer Act. Nestle, on the other hand, argues that the administrative agencies acted arbitrarily and with grave abuse of discretion. The Supreme Court emphasized that certiorari should only be granted when there is a lack or excess of jurisdiction or grave abuse of discretion. The case involves a defect of jurisdiction and centers on whether there is substantial evidence to prove Nestle's violation of the Consumer Act.

ISSUES:

  1. Whether the Court of Appeals properly ruled that the Department of Health (DOH) committed grave abuse of discretion amounting to lack or excess of jurisdiction.

  2. Whether the Court of Appeals has the authority to make its own factual determination when the findings of the administrative officials are arbitrary or in disregard of evidence.

  3. Whether the findings of the Department of Health (DOH), as supported by the Bureau of Food and Drugs (BFAD) and the Court of Appeals (CAO-NCR), can be set aside by the court.

  4. Whether Nestle failed to provide sufficient evidence to prove that it is not responsible for the adulteration of the milk product.

RULING:

  1. The evidence available before the DOH and the CAO-NCR were sufficient and substantial to hold Nestle liable for violating Article 23(3) of RA 7394. The Court found that the CA erred in evaluating the evidence on record and dwelling on errors in judgment committed by the DOH instead of errors of jurisdiction as required in a special civil action for certiorari.

  2. The findings of fact of an administrative body, such as the DOH, are binding on the court if they are duly supported by substantial evidence. The court accords great weight, if not finality, to the findings of administrative bodies due to their specialized expertise in their respective fields. The DOH's decision is supported by substantial evidence, and there is no grave abuse of discretion on its part.

  3. Nestle failed to meet the required burden of proof to persuade the court that it is not responsible for the spoilage or adulteration of the milk product. The self-serving postulations and denial of Nestle, without sufficient evidence, could not outweigh the findings of Jarra and the BFAD's Report of Analysis.

PRINCIPLES:

  • A writ of certiorari may only issue to correct errors in jurisdiction or when there is grave abuse of discretion amounting to lack or in excess of jurisdiction.

  • The main function of a writ of certiorari is limited to keeping the lower courts or quasi-judicial bodies within their jurisdiction and cannot be issued for any other purpose.

  • 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.

  • In the resolution of a petition for certiorari, it is not within the ambit of the appellate court's jurisdiction to inquire into the correctness of the administrative agency's evaluation of evidence, unless such was done with grave abuse of discretion.

  • A petition for review on certiorari is only limited to questions of law.

  • The doctrine of conclusiveness of administrative findings of fact requires the courts to accord great respect and even finality to the factual findings of administrative agencies.

  • Doctrine of conclusiveness of administrative findings of fact: Courts accord great weight, if not finality, to findings of fact of administrative bodies when supported by substantial evidence. Administrative bodies are specialists in their respective fields and can resolve cases with expertise and dispatch.

  • Substantial evidence: More than a mere scintilla but such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. It would suffice to hold one administratively liable.

  • Presumption of technical expertise: Administrative bodies like the BFAD are presumed to possess technical expertise in their given field, and their findings cannot be peremptorily set aside.

  • Welfare of consumers: The welfare of the consumers or the "unsuspecting public" is of paramount importance over the rights of the manufacturer.