Purcon filed a complaint against MRM Philippines for reimbursement of medical expenses and disability benefits due to a hernia he developed while working for them. The labor arbiter dismissed the complaint, finding no merit. Purcon appealed to the Supreme Court using Rule 38, which allows relief from judgment in "any court" due to fraud, accident, mistake, or negligence. However, the Supreme Court ruled that Rule 38 does not apply to the Supreme Court, as it only refers to lower trial courts. It also noted that the Supreme Court only entertains questions of law, not factual inquiries into fraud or other issues, as a petition for relief would require.
Purcon filed a complaint against MRM Philippines for reimbursement of medical expenses and disability benefits due to a hernia he developed while working for them. The labor arbiter dismissed the complaint, finding no merit. Purcon appealed to the Supreme Court using Rule 38, which allows relief from judgment in "any court" due to fraud, accident, mistake, or negligence. However, the Supreme Court ruled that Rule 38 does not apply to the Supreme Court, as it only refers to lower trial courts. It also noted that the Supreme Court only entertains questions of law, not factual inquiries into fraud or other issues, as a petition for relief would require.
Purcon filed a complaint against MRM Philippines for reimbursement of medical expenses and disability benefits due to a hernia he developed while working for them. The labor arbiter dismissed the complaint, finding no merit. Purcon appealed to the Supreme Court using Rule 38, which allows relief from judgment in "any court" due to fraud, accident, mistake, or negligence. However, the Supreme Court ruled that Rule 38 does not apply to the Supreme Court, as it only refers to lower trial courts. It also noted that the Supreme Court only entertains questions of law, not factual inquiries into fraud or other issues, as a petition for relief would require.
FACTS Petitioner Purcon alleged that MRM Philippines, Inc. hired him as a seaman. Few months later, he felt an excruciating pain in his left testicle, which turned out to be hernia following an examination in France. He was repatriated due to this ailment. Back in the Philippines, he was examined by the company physician, who later on declared him fit to resume work. When he reported to MRM, he was told there was no vacancy for him. Purcon filed a complaint for reimbursement of medical expenses, sickness allowance and permanent disability benefits with prayer for various damages and attorney’s fees before the Arbitration Branch of the NLRC. Respondents countered that since hernia was not work-related, he was not entitled to disability benefit and related claims. More importantly, petitioner signed a Quitclaim and Release which was notarized. Labor Arbiter Donato G. Quinto, Jr. rendered its decision dismissing the complaint for utter lack of merit. When the case reached the Supreme Court, Purcon then filed the instant petition for relief from judgment under Rule 38 which states that, “when a judgment or final order is entered, or any other proceeding is thereafter taken against a party in any court through fraud, accident, mistake, or excusable negligence, he may file a petition in such court..."
ISSUE Whether or not the phrase “in any court” comprehends the Supreme Court.
RULING NO. A petition for relief from judgment is not an available remedy in the Supreme Court. while Rule 38 uses the phrase "any court," it refers only to Municipal/Metropolitan and Regional Trial Courts. The procedural change in Rule 38 is in line with Rule 5, prescribing uniform procedure for Municipal and Regional Trial Courts and designation of Municipal/Metropolitan Trial Courts as courts of record. The Supreme Court entertains only questions of law. A petition for relief raises questions of facts on fraud, accident, mistake, or excusable negligence, which are beyond the concerns of this Court.