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, Paulino Estacio and Mario Dulatre. During preliminary conferences, Engineer Estacio, representing the company, admitted liability and agreed to settle the claims by a specific date. Based on this admission and the subsequent failure to pay as promised, both Labor Arbiters issued orders granting the workers’ monetary claims. Petitioner appealed to the NLRC, arguing it was denied due process as the engineers had no authority to represent or bind the company, and that it was not properly served with summons.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the Labor Arbiters’ decisions, which were based on the unauthorized admissions of petitioner’s project engineers, thereby allegedly depriving petitioner of due process.

RULING

The Supreme Court dismissed the petition, affirming the NLRC’s decision. The Court held that service of summons upon the project engineers was valid under the rules, as they were agents of the corporation upon whom service could be properly made. The engineers’ active participation in the proceedings, including admissions of liability and promises to pay, bound the corporation.
The legal logic is anchored on the principle of estoppel and the liberal application of procedural rules in labor cases. While petitioner denied the engineers’ authority, its failure to appear and repudiate their actions during the hearings constituted a waiver. The Labor Arbiters correctly relied on the engineers’ admissions as a valid basis for judgment. The NLRC and its arbiters are not strictly bound by technical rules of procedure and evidence; they may rely on admissions and stipulations made during conferences to expedite labor dispute resolution. The Court found no grave abuse of discretion, as the decisions were grounded on the facts presented during the mandatory conferences, and petitioner was afforded, but failed to utilize, the opportunity to be heard.