G.R. No. 72145 February 28, 1990
MA. EPPIE EDEN, GWEN RELLIN NGOLABAN, and SHARE AND CARE APOSTOLATE FOUNDATION, INC., petitioners, vs. MINISTRY OF LABOR AND EMPLOYMENT and ELLEN ARENDAIN, respondents.

FACTS

Private respondent Ellen Arendain filed a complaint for illegal dismissal against “Share and Care Apostolate for Poor Settlers (SCAPS), c/o Msgr. Patricia Alo.” Notices and subpoenas for conciliation hearings were addressed to petitioner Ma. Eppie Eden as Officer-in-Charge of SCAPS. Petitioners Eden and Ngolaban, along with their counsel, failed to appear at the scheduled hearings despite service of notices. Consequently, the MOLE Regional Director issued an order finding that petitioners waived their right to participate, declared the dismissal illegal, and ordered reinstatement with backwages. Petitioners later moved for reinvestigation, claiming lack of proper notice and that Arendain was a volunteer, not an employee. They also argued that the judgment improperly bound Share and Care Apostolate Foundation, Inc. (SCAFI), which was not named as a party, and held Eden and Ngolaban personally liable.

ISSUE

Whether petitioners were denied due process in the MOLE proceedings, warranting nullification of the assailed orders.

RULING

The Supreme Court ruled that petitioners were not denied due process. The essence of due process in administrative proceedings is notice and an opportunity to be heard. The records substantiated that multiple notices for conciliation hearings were duly served at SCAPS’s office, which petitioners chose to ignore. Their counsel’s appearance at one hearing further negated any claim of lack of notice. Their voluntary non-participation constituted a waiver of their right to be heard. Regarding the party-identity issue, the Court found no fatal error. SCAPS was identified as the implementing arm of SCAFI, with shared leadership and address. SCAFI, possessing juridical personality, was the real party in interest. The alteration in caption from SCAPS to SCAFI was a formal correction that did not prejudice petitioners, as SCAFI was never a stranger to the case. Moreover, SCAFI’s three-year silence after receiving the 1980 order implied submission to the MOLE’s jurisdiction. On the personal liability of Eden and Ngolaban, the Court upheld the finding that they effected the dismissal due to personal differences, making them jointly and severally liable with SCAFI as employers. Procedural technicalities on summons are applied liberally in quasi-judicial bodies, with substantial compliance being sufficient. The petition was dismissed for lack of merit.