G.R. No. 124723 July 31, 1998
MARCELINO S. SUAREZ and ARNOLD C. NEBRES, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION and MANILA ELECTRIC COMPANY, respondents.

FACTS

Petitioners Marcelino S. Suarez and Arnold C. Nebres were employed as draftsmen by respondent Manila Electric Company (MERALCO). On March 20, 1991, based on an anonymous tip that they were seen “smoking something” (suspected to be “shabu”), company security personnel invited them, with their supervisors’ consent, to the John F. Cotton Hospital for clinical evaluation under the company’s Drug Abuse Policy. Petitioners signed “Consent for Hospital Care” forms and submitted urine samples. The initial test at the company hospital was positive for cannabinoids (marijuana). They were then referred to the Philippine National Police Crime Laboratory Service (PNPCLS) in Camp Crame, accompanied by union officers, where another test also yielded positive results for marijuana. Based on these findings and after administrative proceedings, petitioners were dismissed on September 4, 1991, for violating the Company Code on Employees Discipline and the Drug Abuse Policy. They filed a complaint for illegal dismissal. The Labor Arbiter, after the parties submitted position papers and documents without a formal trial, rendered a decision declaring the dismissal valid and justified. The NLRC affirmed this decision en toto and denied the motion for reconsideration.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the Labor Arbiter’s decision which resolved the labor dispute solely on the basis of position papers and documents, without conducting a formal trial.

RULING

The Supreme Court DISMISSED the petition for lack of merit. The Court held that the NLRC did not commit grave abuse of discretion. The Labor Code (Article 221) and the NLRC Rules of Procedure (Section 4, Rule V) allow Labor Arbiters to decide cases based on position papers and documents without resorting to the technical rules of evidence or formal hearings. The holding of a trial is discretionary on the Labor Arbiter and cannot be demanded as a matter of right. The record showed petitioners agreed to submit the case for resolution after filing their pleadings. Furthermore, the factual findings of quasi-judicial agencies like the NLRC, when supported by substantial evidence and absent any showing of arbitrariness, are accorded respect and finality. The Court found no reason to overturn the conclusion that the dismissal was valid, as the positive drug test results constituted substantial evidence for the dismissal. Petitioners’ collateral claims regarding union activity and alleged violation of rights to privacy were not proper for resolution as they were not triers of fact and these issues were not raised in the lower forums.