G.R. No. 254976 , August 20, 2024
MARCELINO DELA CRUZ LINGGANAY, PETITIONER, VS. DEL MONTE LAND TRANSPORT BUS COMPANY, INC. AND NARCISO MORALES, RESPONDENTS.

FACTS

Petitioner Marcelino Dela Cruz Lingganay filed a complaint for illegal dismissal against respondents. Prior to filing his Position Paper, he had at least four opportunities to comprehensively inform the respondents of his claims, including for separation pay, holiday premium, rest day pay, and underpaid wages: (1) in his original Complaint; (2) in his Amended Complaint dated July 13, 2017; (3) by filing a second amended complaint before the filing of his Position Paper pursuant to the NLRC Rules; and (4) by bringing up the claims during the Mandatory Conciliation and Mediation Conference. However, Lingganay only sought to amend his complaint by incorporating a motion to further amend and a second amended complaint in his Position Paper. His sole justification for this procedural lapse was the Court’s ruling in the Our Haus case, which stated a claim not raised in the pro forma complaint may still be raised in the position paper. He offered no explanation for disregarding the NLRC Rules.

ISSUE

Whether the Labor Arbiter correctly denied the petitioner’s belated motion to amend his complaint, which was filed only with his Position Paper, for failure to follow the procedural rules set by the NLRC.

RULING

The Concurring Opinion votes to DENY the Petition. The NLRC has the power to promulgate rules to ensure the speedy disposition of cases. The 2011 NLRC Rules were amended to require that all causes of action and amendments to a complaint be threshed out during the mandatory conference before position papers are filed. This is to fully apprise the other party, avoid surprises and injustice, and prevent needless delays. Lingganay failed to avail himself of multiple earlier opportunities to amend his complaint and offered no sufficient reason or special circumstances to justify his disregard of the rules. Without a compelling reason, the Court should not accommodate his belated amendment, as the Labor Arbiter is empowered to exercise discretion in such matters to prevent delays. The ruling in Our Haus does not sanction the disregard of the specific procedural changes introduced by the NLRC.