G.R. No. L-60950 November 19, 1982
J.D. MAGPAYO CUSTOMS BROKERAGE CORPORATION, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION AND FRANCISCO GRANATAN, respondents.

FACTS

Private respondent Francisco Granatan filed a complaint for illegal dismissal and non-payment of wages against his employer, petitioner J.D. Magpayo Customs Brokerage Corporation. In a decision dated March 10, 1981, the Labor Arbiter ruled in favor of Granatan, ordering his reinstatement without loss of seniority rights and the payment of back wages. The petitioner employer timely appealed this adverse decision to the National Labor Relations Commission (NLRC).
The NLRC, however, dismissed the appeal outright. The sole ground for dismissal was the petitioner’s failure to show that it had served a copy of its appeal memorandum upon the appellee, Granatan. The NLRC found that “there is no showing whatsoever that a copy of the appeal was served by the appellant on the appellee.” The petitioner then elevated the matter to the Supreme Court via certiorari, arguing that the NLRC committed grave abuse of discretion.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in dismissing the petitioner’s appeal solely for failure to serve a copy of the appeal memorandum on the adverse party.

RULING

Yes, the NLRC committed grave abuse of discretion. The Supreme Court granted the petition, setting aside the NLRC’s order of dismissal and directing the Commission to give due course to the appeal.
The Court ruled that the failure to serve a copy of the appeal on the adverse party was a mere formal lapse constituting excusable neglect. It emphasized that procedural rules should not be applied rigidly to defeat substantial justice, especially in labor cases where a more liberal interpretation is favored. The Court drew an analogy to its own practice of acting on petitions for review from the Court of Appeals even when the petitioner initially fails to submit proof of service, simply requiring subsequent compliance.
Jurisprudential support was found in Estrada vs. National Labor Relations Commission, where the Court previously set aside an NLRC order dismissing an appeal on the identical ground. The decision in Estrada quoted Chief Justice Enrique Fernando’s opinion in Meracap v. International Ceramics Mfg. Co., Inc., which stressed that labor determinations should be based on informed judgment and equity, not rigid rules. The Court concluded that the NLRC’s outright dismissal for a procedural oversight, without considering the merits or the equities of the case, was a grave abuse of discretion warranting corrective action. The substantive right to appeal should not be forfeited for such a technicality.