G.R. No. 118101. September 16, 1996. EDDIE DOMASIG, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION (SECOND DIVISION), CATA GARMENTS CORPORATION and/or OTTO ONG and CATALINA CO., respondents.
FACTS:

Petitioner Eddie Domasig filed a complaint for illegal dismissal, unpaid commissions, and other monetary claims against Cata Garments Corporation and its owners. He alleged he started working as a salesman in 1986, receiving a monthly salary plus commissions, and was dismissed in 1992 after refusing an offer from a rival corporation. The respondents contended Domasig was merely a commission agent with no regular hours, receiving a fixed monthly allowance of P1,500 plus piece-rate commissions, and that the corporation itself was established only in 1991. They also alleged he failed to remit collections, leading to criminal charges.
The Labor Arbiter ruled in favor of Domasig, declaring his dismissal illegal and awarding reinstatement, backwages, monetary benefits, and unpaid commissions totaling P143,955. On appeal, the NLRC set aside this decision and remanded the case to the arbitration branch for further proceedings. The NLRC found the Arbiter’s decision unsupported by evidence, specifically failing to resolve the crucial issue of whether Domasig was an employee or a commission agent based on exhibits submitted by the respondents.

ISSUE

Whether the NLRC committed grave abuse of discretion in vacating the Labor Arbiter’s decision and remanding the case for further proceedings.

RULING

Yes, the NLRC committed grave abuse of discretion. The Supreme Court held that the Labor Arbiter’s finding of an employer-employee relationship was based on substantial evidence, which is sufficient in labor cases. This evidence included an identification card issued by the company and cash vouchers reflecting regular monthly salary allowances. The Court emphasized that no particular form of evidence is required to prove such a relationship, and the continuous service for over one year qualified Domasig as a regular employee.
The NLRC’s order for remand to re-examine this settled issue would unjustly prolong the disposition, contrary to the mandate for speedy labor justice. The Labor Arbiter and NLRC possess broad authority to decide cases based on position papers and documents without strict adherence to technical rules. However, the Court modified the Arbiter’s decision regarding the award for unpaid commissions. It directed a re-computation by the Labor Arbiter within thirty days, considering the exhibits on record and the dismissal of the criminal cases against Domasig, to determine the exact amount lawfully due. Thus, the NLRC resolutions were set aside and the Labor Arbiter’s decision reinstated, subject to the modification on commission recomputation.