G.R. No. 153660 ; June 10, 2003
PRUDENCIO BANTOLINO, ET AL., petitioners, vs. COCA-COLA BOTTLERS PHILS., INC., respondent.

FACTS

Sixty-two employees initially filed a complaint against Coca-Cola Bottlers Phils., Inc. and several service contractors for illegal dismissal, unfair labor practice, and regularization. The Labor Arbiter dismissed the claims of fifty-two complainants for failure to prosecute. For the ten remaining petitioners, the Labor Arbiter conducted clarificatory hearings. Petitioners testified they performed duties as route helpers and bottle segregators directly for respondent, and were prevented from entering company premises, constituting illegal dismissal. Respondent moved to dismiss, arguing no employer-employee relationship existed as petitioners were employed by independent contractors.
The Labor Arbiter ruled in favor of petitioners, finding an employer-employee relationship and ordering reinstatement with full back wages. The NLRC affirmed this decision in toto. On appeal, the Court of Appeals affirmed the existence of an employer-employee relationship but dismissed the complaints of seven petitioners (Bantolino, Romero, Espina, Bartolome, Eluver Garcia, Eduardo Garcia, and Manalastas). The appellate court held their sworn affidavits lacked probative value because they were not presented for cross-examination during the clarificatory hearings. Only complainants Ladica, Queling, and Nieto, who were cross-examined, were declared regular employees.

ISSUE

Whether the Court of Appeals erred in disregarding the sworn affidavits of the seven petitioners for their failure to undergo cross-examination.

RULING

Yes. The Supreme Court reversed the Court of Appeals and reinstated the NLRC decision, with the modification that the petition concerning Nestor Romero was denied due to a valid compromise agreement. The Court held that the technical rules of evidence prevailing in courts of law do not strictly apply in labor proceedings. The Labor Code and the NLRC Rules of Procedure mandate that proceedings before labor arbiters are non-litigious in nature. Labor arbiters are directed to use every reasonable means to ascertain the facts speedily and objectively, without regard to technicalities of law or procedure.
The Labor Arbiter in this case properly exercised his authority to conduct clarificatory hearings to ascertain the truth. The sworn statements of the petitioners constituted substantial evidence to support their claims. Requiring rigid cross-examination as a condition for giving probative value to affidavits would undermine the intent of labor laws to provide accessible and expeditious settlement of disputes. The Court emphasized that the affidavits contained detailed accounts of their employment, which sufficiently established the employer-employee relationship with respondent. Therefore, the Court of Appeals erred in applying strict rules on cross-examination to dismiss their complaints.