G.R. No. 121466 August 15, 1997
PMI COLLEGES, petitioner, vs. THE NATIONAL LABOR RELATIONS COMMISSION and ALEJANDRO GALVAN, Respondents.

FACTS

Petitioner PMI Colleges hired private respondent Alejandro Galvan as a contractual instructor in July 1991, with compensation based on an hourly rate. Galvan organized and taught classes in marine engineering. Initially, he and other instructors were paid, but payments for subsequent services were withheld. This non-payment was documented in a March 3, 1992 letter from PMI’s Acting Director to its President, appealing for the release of salaries, including those for Galvan’s shipyard visits and on-the-job training. As repeated demands failed, Galvan filed a complaint with the NLRC in September 1993, seeking payment for unpaid wages from specific classes, training sessions, and his service as Acting Director. He submitted substantial documentary evidence, including class schedules, the internal letter requesting payment, and prepared but unpaid vouchers.
PMI Colleges resisted the claims, arguing the classes were not held on its premises, that it exercised no supervision over the activities—which it alleged violated DECS rules—and that Galvan had abandoned his work. Galvan countered that lectures were conducted within PMI’s rented space, students were officially enrolled, and the shipyard visits were known to and facilitated by PMI. During proceedings, PMI also raised an internal by-law issue, claiming only its Chairman was authorized to sign contracts. The Labor Arbiter decided the case based on position papers, over PMI’s objection for a formal trial. The Arbiter ruled for Galvan, a decision affirmed in toto by the NLRC.

ISSUE

The core issues were whether Galvan’s money claims had valid legal and factual bases and whether PMI was denied procedural due process by the Labor Arbiter’s decision based on position papers without a formal trial.

RULING

The Supreme Court dismissed the petition and affirmed the NLRC resolution. On the substantive claims, the Court upheld the findings of the Labor Arbiter and the NLRC, emphasizing that factual findings of administrative agencies, when supported by substantial evidence, are accorded respect and finality. Galvan presented compelling documentary evidence, including PMI’s own internal correspondence acknowledging the debt, which substantiated his claims for services rendered. PMI’s defenses, such as the alleged violation of DECS rules or internal authorization issues, did not negate the existence of an employer-employee relationship and the obligation to pay for services admittedly received. The by-law restriction on contract signing was deemed an internal matter that could not prejudice a third party who rendered services in good faith.
On procedural due process, the Court ruled PMI was not denied its right. The essence of due process is a reasonable opportunity to be heard. The Labor Arbiter provided this by requiring and accepting position papers accompanied by all supporting documents, as mandated by the rules. The Court noted that PMI was even granted a motion to submit additional documents. Its failure to fully proffer all its evidence, such as affidavits of witnesses which could have been included in its position paper, was its own omission. A formal trial is not indispensable when the case can be resolved based on the pleadings and submitted evidence. Therefore, the Labor Arbiter and NLRC committed no grave abuse of discretion.