GR 124500; (December, 1998) (Digest)
G.R. No. 124500 December 4, 1998
PHILIPPINE SCOUT VETERANS SECURITY AND INVESTIGATION AGENCY, INC., RICARDO BONA and SEVERO SANTIAGO, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION and FLORENTINO LAMSEN, respondents.
FACTS
Florentino Lamsen, a security guard employed for over thirty-one years by Philippine Scout Veterans Security and Investigation Agency, Inc. (PSVSIA), filed a complaint for underpayment of wages and overtime pay. He presented a detailed schedule alleging his daily wage rates from 1991 to 1994 remained below the statutory minimum. Petitioners initially moved to dismiss, claiming Lamsen was employed by an affiliate agency, but later shifted their defense in their position paper, asserting full payment. They submitted photocopies of random payroll samplings as proof.
The Labor Arbiter ruled in Lamsen’s favor, ordering payment of underpaid wages and overtime. On appeal, the NLRC modified the award’s retroactivity. Before the NLRC, petitioners moved for reinvestigation and offered to submit the original payrolls containing Lamsen’s signatures to authenticate their photocopies and disprove underpayment. The NLRC denied this motion, questioning the authenticity of the unsigned photocopies but refusing to examine the originals.
ISSUE
Did the NLRC commit grave abuse of discretion in denying petitioners the opportunity to present original payroll documents and in holding corporate officers personally liable?
RULING
Yes, the NLRC committed grave abuse of discretion. Article 221 of the Labor Code mandates that technical rules of evidence are not controlling; labor tribunals must use all reasonable means to ascertain facts speedily and objectively. By doubting the authenticity of the payroll photocopies due to missing signatures and then denying petitioners’ motion to submit the signed originals, the NLRC rigidly applied procedural technicalities. This contravened the Labor Code’s spirit and prevailing jurisprudence, which requires that procedure not hinder the equitable and complete resolution of parties’ rights. The NLRC should have allowed the submission of original documents to properly determine the factual issue of underpayment. Furthermore, it gravely abused its discretion in holding the corporate officer and stockholder personally and jointly liable without any proof of malice or bad faith. The case was remanded to the NLRC to receive the original payrolls and resolve the matter with dispatch.