G.R. No. 173648; January 16, 2012
ABDULJUAHID R. PIGCAULAN, Petitioner, vs. SECURITY and CREDIT INVESTIGATION, INC. and/or RENE AMBY REYES, Respondents.

FACTS

Petitioner Abduljuahid R. Pigcaulan and Oliver R. Canoy were employed as security guards by respondent Security and Credit Investigation, Inc. (SCII). They filed separate complaints (later consolidated) with the Labor Arbiter for underpayment of salaries and non-payment of overtime, holiday, rest day, service incentive leave, and 13th month pays. In support, they submitted their daily time records and itemized lists of their claims. Respondents SCII and its General Manager Rene Amby Reyes maintained that the complainants were paid their just salaries and benefits above the statutory minimum, that holiday pay was included in their monthly salaries, and that they received premium pay for work on Sundays and holidays. As proof, respondents submitted payroll listings and lists of employees who received 13th month pay for 1998 and 1999, arguing that claims should be limited to the past three years due to prescription.
The Labor Arbiter awarded monetary claims to Canoy and Pigcaulan, finding the payroll listings unsigned and thus lacking probative value, but acknowledged the signed 13th month payroll as proof of payment. The NLRC dismissed respondents’ appeal and sustained the Labor Arbiter’s decision. The Court of Appeals (CA) set aside the NLRC and Labor Arbiter’s rulings, dismissing all monetary claims. The CA found no factual or legal bases in the decisions, noting the Labor Arbiter disregarded the rule requiring detailed computation of awards, incorrectly stated the payrolls were unsigned when they bore Canoy’s signatures, failed to state the substance of evidence or applicable laws, and held Reyes solidarily liable without proof of malicious design to evade corporate obligations. Pigcaulan alone filed the present Petition for Review on Certiorari after the CA denied reconsideration.

ISSUE

Whether the Court of Appeals erred in dismissing the complaint based on the alleged failure of the Labor Arbiter and NLRC to observe prescribed decision forms and due to absence of legal and factual bases, despite the presence of substantial evidence.

RULING

The Supreme Court granted the petition, reversed the CA Decision, and reinstated the NLRC Resolution affirming the Labor Arbiter’s Decision, with modification regarding solidary liability.
The Court held that technical rules of procedure are not strictly applied in labor cases. While the Labor Arbiter’s decision lacked a detailed computation, it substantially complied with rules by stating the nature and specific amounts awarded. The omission of a detailed breakdown did not justify the CA’s outright dismissal; the case should have been remanded for recomputation if necessary. On the merits, the burden of proving payment of statutory benefits rests on the employer. Respondents failed to substantiate their claim of payment with convincing evidence. The payrolls submitted were not signed by the complainants or any SCII officer, and the transmittal letters to banks were insufficient to prove actual receipt of salaries by the specific employees. The complainants’ itemized computations and daily time records constituted substantial evidence to support their claims for salary differentials and service incentive leave pay. However, the claim for 13th month pay for 2000 was correctly dismissed as the complainants did not work for the entire year. Regarding solidary liability, the Court ruled that corporate officers can be held jointly and severally liable with the corporation for the latter’s debts arising from illegal dismissal or unpaid wages. Since the complaint included a money claim for unpaid wages, the allegation of solidary liability against Reyes was proper. The case was remanded to the Labor Arbiter for recomputation of the exact amounts due.