G.R. Nos. 117442-43, January 11, 1995
FEM’S ELEGANCE LODGING HOUSE, FENITHA SAAVEDRA and IRIES ANTHONY SAAVEDRA, petitioners, vs. The Honorable LEON P. MURILLO, Labor Arbiter, Regional Arbitration Branch, Region X, National Labor Relations Commission, Cagayan de Oro City, ALFONSO GALLETO, et al., respondents.

FACTS

Petitioners, the owners and managers of FEM’s Elegance Lodging House, were sued by their former employees (private respondents) for various monetary claims before the National Labor Relations Commission (NLRC). During a pre-arbitration conference, the parties agreed to consolidate the cases and submit their respective position papers by June 30, 1994. Petitioners filed their position paper on June 29. Upon inquiry on July 7, they learned that private respondents had not yet filed theirs. Petitioners thus filed a Motion to Dismiss on July 8. Private respondents belatedly filed their position paper on July 15. Petitioners subsequently filed a Motion to Expunge the late-filed position paper. The Labor Arbiter, however, denied both motions in an Order dated September 21, 1994, holding that a 15-day delay was not unreasonable and that substantive rights should not be sacrificed by technicality, invoking the rule of construction in favor of labor under Article 4 of the Labor Code.

ISSUE

Whether the Labor Arbiter committed grave abuse of discretion in denying the petitioners’ Motion to Dismiss and Motion to Expunge the private respondents’ belatedly filed position paper.

RULING

The Supreme Court dismissed the petition. The primary ground for dismissal was the petitioners’ failure to exhaust administrative remedies. Under Article 223 of the Labor Code, orders of the Labor Arbiter are appealable to the NLRC. By filing a petition for certiorari directly with the Supreme Court, petitioners bypassed the proper appellate review, rendering their petition premature and procedurally infirm. Even assuming the petition was properly filed, the Court found no merit in the petitioners’ arguments. The Labor Arbiter did not commit grave abuse of discretion. Technical rules of procedure are not strictly applied in labor cases. The delay in filing a position paper is a procedural lapse that the Labor Arbiter may overlook in the interest of substantial justice. Notably, the failure to submit a position paper on time is not among the grounds for dismissing a complaint under the NLRC Rules. The policy of the State is to afford protection to labor, and all doubts in the interpretation of labor laws are resolved in favor of workers. Petitioners’ claim of denial of due process was unfounded, as they were able to fully present their position. The proper resolution of the case on its merits, rather than on a technicality, would best serve the interests of justice for all parties involved.