G.R. No. 206612, August 17, 2015
TOYOTA ALABANG, INC., PETITIONER, VS. EDWIN GAMES, RESPONDENT.

FACTS

Respondent Edwin Games, a foreman at petitioner Toyota Alabang, Inc., was found on December 14, 2005, with a box of the company’s expensive vehicle lubricants in his car during a routine inspection. An information for frustrated qualified theft was filed. Games later filed a complaint for illegal dismissal. The Labor Arbiter ruled in favor of Games, awarding monetary benefits, after petitioner’s previous counsel allegedly failed to attend hearings or file pleadings. Petitioner, through new counsel, filed a motion to quash the writ of execution and sought to reopen the case. The Labor Arbiter denied the motion. Petitioner filed a memorandum of appeal with the NLRC, attaching a “Certificate of Security Deposit” from Visayan Surety and Insurance Corporation. The NLRC denied the appeal for failure to attach an “assignment of bank deposit” as proof of the appeal bond. The Court of Appeals dismissed petitioner’s certiorari petition. The Supreme Court initially denied petitioner’s petition for review. Petitioner filed a motion for reconsideration.

ISSUE

1. Whether the Certificate of Security Deposit constituted sufficient proof of security deposit under the NLRC Rules.
2. Whether the gross negligence of petitioner’s previous counsel amounted to a denial of due process.
3. Whether the Court should relax procedural rules to address the substantive merits of the case regarding the validity of Games’ dismissal.

RULING

Justice Bersamin, in his dissenting opinion, voted to GRANT the motion for reconsideration and remand the case to the Labor Arbiter for reception of evidence.
1. The Certificate of Security Deposit was sufficient proof under Section 6(c), Rule VI of the 2005 NLRC Rules, which only requires “proof of security deposit or collateral securing the bond” and does not specify an assignment of bank deposit. The NLRC’s requirement thereof constituted grave abuse of discretion. Furthermore, the bond requirement does not apply to appeals from an order denying a motion to quash a writ of execution, as such an order is not a monetary award.
2. The negligence of petitioner’s previous counsel, which prevented petitioner from meaningfully participating in the proceedings, warranted treating its appeal as a petition for relief from judgment. Denying the motion for reconsideration would fixate on technicalities and overlook substantial merits.
3. The dismissal of Games rested on substantial grounds, as he was allegedly caught in flagrante delicto stealing company property, constituting serious misconduct or a crime against the employer under the Labor Code. The constitutional policy to protect labor should not oppress management or prevent sustaining an employer when it is in the right. The Court, as a court of law and justice, should relax the rule on finality of judgments in meritorious circumstances to serve substantial justice.