GR 165442; (August, 2010) (Digest)
G.R. No. 165442; August 25, 2010
NASECO GUARDS ASSOCIATION-PEMA (NAGA-PEMA), Petitioner, vs. NATIONAL SERVICE CORPORATION (NASECO), Respondent.
FACTS
Respondent National Service Corporation (NASECO) is a corporation supplying security and manpower services. Petitioner NASECO Guards Association-PEMA (NAGA-PEMA) is the collective bargaining representative of its regular security guards. Following a bargaining deadlock and notices of strike, the Secretary of Labor assumed jurisdiction and, in a 1999 Resolution, directed the parties to execute a new Collective Bargaining Agreement (CBA) with specified economic benefits. NASECO challenged this before the Court of Appeals (CA), arguing the award would force it to close. The CA, in a 2001 Decision, partly granted the petition and remanded the case to the DOLE Secretary for “recomputation and reevaluation of the CBA benefits.”
On remand, DOLE Secretary Patricia Sto. Tomas conducted clarificatory hearings and issued a 2003 Order, which affirmed the 1999 award after a revised computation showed a lower total cost. NASECO again petitioned the CA, arguing the Secretary merely recomputed the figures without a true reevaluation and that it was denied due process as it was not allowed to formally present evidence on the company’s financial capacity.
ISSUE
Whether the Court of Appeals erred in ruling that the DOLE Secretary violated NASECO’s right to due process by not allowing the formal presentation of evidence during the remand for recomputation and reevaluation.
RULING
Yes, the Court of Appeals erred. The Supreme Court reversed the CA and reinstated the DOLE Secretary’s 2003 Orders. The legal logic is that the remand to the DOLE Secretary was for the specific purpose of “recomputation and reevaluation,” not for a full-blown rehearing or the reception of new, previously unavailable evidence. The Secretary complied by conducting clarificatory hearings where both parties, including NASECO, were given the opportunity to explain their positions and submit supporting documents on the financial implications of the award. Due process in administrative proceedings is satisfied by the opportunity to be heard, not necessarily by trial-type proceedings. The essence of the CA’s initial directive was to ensure the award’s financial reasonableness, a task the Secretary performed by examining the existing records and the submissions made during the clarificatory process. Allowing a full re-litigation of evidentiary matters at that stage would be contrary to the nature of the Secretary’s power of assumption of jurisdiction, which is intended to expedite the resolution of labor disputes.