GR 157371; (July, 2005) (Digest)
G.R. No. 157371 . July 15, 2005
ELMER G. ANDAYA, Petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, INTERNATIONAL HAM & SAUSAGE MANUFACTURING CO., INC., Respondents.
FACTS
Petitioner Elmer Andaya, along with co-workers, filed a complaint for illegal dismissal and monetary claims against respondent company. The Labor Arbiter ruled in their favor, awarding them service incentive leave pay, holiday pay, and overtime pay. The company filed a partial appeal before the NLRC. On appeal, the company submitted new evidence, specifically a Collective Bargaining Agreement (CBA) and payroll documents, to prove that the petitioner had already received the claimed benefits. These documents were not presented during the proceedings before the Labor Arbiter.
The NLRC admitted the new evidence, reversed the Labor Arbiter’s decision, and deleted all monetary awards. The NLRC found that the payroll, bearing the petitioner’s signature, indicated payment of the benefits. Petitioner challenged this before the Court of Appeals via certiorari, arguing that the NLRC gravely abused its discretion by admitting evidence only on appeal and by disregarding his evidence, which consisted of logbook entries. The CA dismissed the petition, prompting this appeal.
ISSUE
Whether the Court of Appeals erred in affirming the NLRC Decision which reversed the Labor Arbiter’s award, particularly regarding the admission of evidence on appeal and the evaluation of the evidentiary weight of the submitted documents.
RULING
The Supreme Court denied the petition, affirming the rulings of the NLRC and the CA. The Court held that technical rules of procedure are not strictly applied in labor cases to serve the ends of substantial justice. The NLRC did not commit grave abuse of discretion in admitting the CBA and payroll on appeal, provided due process was observed. The petitioner was given the opportunity to meet and rebut this new evidence, which he failed to effectively do.
On the factual findings, the Court reiterated that it is not a trier of facts. The NLRC’s determination, affirmed by the CA, that the payroll—authenticated by the petitioner’s own signature—proved payment of overtime and holiday pay is binding. The petitioner did not contest the authenticity of his signatures on the payroll. His submitted logbook entries, even if true, did not specifically prove non-payment and were insufficient to controvert the payroll evidence. Consequently, no grave abuse of discretion attended the NLRC’s decision to overturn the Labor Arbiter’s award based on the newly presented and more conclusive evidence.