GR 131467; (April, 1999) (Digest)
G.R. No. 131467 April 21, 1999
BENEDICTO CAÑETE and EDGAR ISABIDA, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION and ABRAHAM ABAJO, respondents.
FACTS
Petitioners Benedicto Cañete and Edgar Isabida were employed as rubber tappers by private respondent Abraham Abajo. They alleged illegal dismissal, claiming they were verbally told to stop working on November 26, 1996, without being informed of any reason. They filed a complaint for illegal dismissal with money claims. The Labor Arbiter ruled in their favor, awarding backwages, separation pay, and other monetary benefits. The Labor Arbiter based his decision on the pleadings and documents submitted by the parties, as the private respondent failed to appear at scheduled hearings despite notice.
Private respondent Abraham Abajo contested the claims, asserting the petitioners were dismissed for valid causes including insubordination, negligence, and habitual absence. He disputed the length of their employment and their daily wage rates. The National Labor Relations Commission (NLRC), on appeal, vacated the Labor Arbiter’s decision and remanded the case for further proceedings. The NLRC held that a clarificatory hearing was necessary due to the seriously disputed factual issues, finding it improbable that an employer would dismiss employees without reason.
ISSUE
Whether the NLRC committed grave abuse of discretion in remanding the case to the Labor Arbiter for further proceedings despite the parties having had full opportunity to present their evidence.
RULING
Yes. The Supreme Court granted the petition, annulling the NLRC resolutions and reinstating the Labor Arbiter’s decision with modification on the computation of backwages. The Court held that the NLRC gravely abused its discretion. The essence of due process in labor cases is simply an opportunity to be heard. The private respondent was given this opportunity but, through his own fault and inaction, failed to fully air his side by not appearing at the hearings before the Labor Arbiter despite notice. Subject to due process, labor arbiters are given wide latitude and may decide cases based on the position papers, pleadings, and documents submitted. A formal or trial-type hearing is not always necessary. The remand of the case was not justified, as it would only delay the resolution and defeat the speedy administration of justice. The Labor Arbiter correctly resolved the case based on the evidence on record, and his findings, which are accorded respect and finality, sufficiently established the illegal dismissal.