GR 134903; (March, 2001) (Digest)
G.R. No. 134903; March 26, 2001
UNICRAFT INDUSTRIES INTERNATIONAL CORPORATION, et al., petitioners, vs. THE HON. COURT OF APPEALS, VOLUNTARY ARBITRATOR FLORANTE V. CALIPAY, et al., respondents.
FACTS
Petitioner Unicraft Industries International Corporation dismissed thirty-two private respondents, its employees, following the closure of its Lapulapu City branch by the city government due to lack of permits. The employees filed complaints for illegal dismissal and monetary claims. The parties agreed to submit the case to voluntary arbitration before Florante V. Calipay. Petitioners later filed a motion for re-selection of arbitrator, which was denied. The voluntary arbitrator set a hearing and ordered the submission of position papers.
Petitioners and their counsel failed to appear at the scheduled hearing. Consequently, the voluntary arbitrator rendered a decision based solely on the employees’ position papers and the records from the prior NLRC case, declaring the dismissals illegal and awarding substantial back wages, separation pay, and monetary claims totaling over six million pesos. The Court of Appeals subsequently issued resolutions ordering the execution of the arbitrator’s award.
ISSUE
Whether the Voluntary Arbitrator committed grave abuse of discretion, violating petitioners’ right to due process, by rendering a decision without affording them an opportunity to present evidence.
RULING
Yes. The Supreme Court granted the petition, annulling the decisions of the Court of Appeals and the Voluntary Arbitrator. The core legal principle is that the right to due process in administrative and quasi-judicial proceedings includes the opportunity to be heard and to present one’s case and evidence. While technical rules of procedure are not strictly applied, fundamental fairness requires that parties be given a meaningful chance to argue their cause.
Here, the Voluntary Arbitrator’s act of deciding the case based exclusively on the submissions of one side, due to the other party’s non-appearance at a single hearing, constituted a denial of this fundamental right. The arbitrator prematurely resolved the merits without allowing petitioners to present countervailing evidence on the critical issues, such as the legality of the dismissal based on the government-ordered closure and the validity of the quitclaims. This procedural lapse rendered the decision null and void. The case was remanded to the Voluntary Arbitrator to receive evidence from the petitioners and conduct proper proceedings, thereby curing the due process violation. The Court of Appeals committed grave abuse of discretion in ordering the execution of a void award.