G.R. No. 126625 September 18, 1997
Kanlaon Construction Enterprises Co., Inc., petitioner, vs. National Labor Relations Commission, 5th Division, and Benjamin Reluya, Jr., et al., respondents.

FACTS

Petitioner Kanlaon Construction, a domestic corporation, was contracted by the National Steel Corporation for a construction project in Iligan City. Private respondents were hired as laborers for this project. In 1990, after their services were terminated, forty-one workers filed separate complaints before the NLRC Sub-Regional Arbitration Branch in Iligan City, claiming underpayment of wages and non-payment of thirteenth-month pay. The cases were assigned to Labor Arbiters Siao and Palangan. Summonses and notices were served on petitioner through its project engineers, Estacio and Dulatre.
During preliminary conferences, Engineers Estacio and Dulatre appeared and represented the company. Before Arbiter Siao, Engineer Estacio admitted petitioner’s liability and agreed to a settlement date. When the company failed to pay as promised, both Arbiters issued orders granting the workers’ claims, citing the engineers’ admissions and the company’s failure to comply with its commitment. Petitioner appealed to the NLRC, arguing it was denied due process as the engineers lacked authority to represent or bind the corporation, and that it was not properly served with notices.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the Labor Arbiters’ decisions which held petitioner liable based on the unauthorized admissions of its project engineers, allegedly in violation of petitioner’s right to due process.

RULING

The Supreme Court dismissed the petition, ruling that the NLRC did not commit grave abuse of discretion. The Court held that service of summons upon the engineers was valid under the Rules of Court, as service upon a corporation may be made on its agent. Engineers Estacio and Dulatre, being the supervisors at the project site who hired and supervised the workers, were considered agents for purposes of receiving court processes. Petitioner’s failure to file a position paper or any responsive pleading, despite being notified through its agents, constituted a waiver of its right to present evidence.
The admissions made by the engineers during the conferences were binding. While a compromise agreement requires special authority, an admission of liability in the course of proceedings does not. The Labor Arbiters properly relied on these judicial admissions, which are conclusive upon the party making them. The NLRC and its arbiters are not strictly bound by technical rules of procedure and evidence; they may rely on admissions and the position of the parties to arrive at a just resolution. Petitioner’s inaction and reliance on its unauthorized counsel for the appeal further estopped it from disclaiming the proceedings. Thus, no denial of due process occurred.