G.R. No. L-27392. January 30, 1971.
PABLO CATURA and LUZ SALVADOR, petitioners, vs. THE COURT OF INDUSTRIAL RELATIONS and CELESTINO TABANIAG, et al., respondents.

FACTS

Petitioners Pablo Catura and Luz Salvador, the President and Treasurer of the Philippine Virginia Tobacco Administration Employees Association, were charged before the Court of Industrial Relations (CIR) by a group of union members led by respondent Celestino Tabaniag. The complaint, filed under Section 17 of the Industrial Peace Act ( Republic Act No. 875 ), alleged that petitioners committed unauthorized disbursements of union funds and repeatedly refused demands from the membership for a full financial report and inspection of the union’s books of accounts, despite exhausting internal union remedies and ignoring subpoenas from the Department of Labor.
Acting on the complaint and a subsequent petition for injunction, CIR Associate Judge Joaquin M. Salvador issued an order dated December 29, 1966, directing petitioners to personally deliver and deposit with the court all the union’s books of accounts, bank records, passbooks, funds, receipts, vouchers, and other financial documents at a scheduled hearing. Petitioners filed a motion for reconsideration, arguing that the order was issued without prior hearing, constituting a denial of procedural due process, and that it exceeded the CIR’s statutory power. The CIR en banc sustained the order, prompting this petition for review.

ISSUE

Whether the Court of Industrial Relations, in exercising its investigative power under Section 17 of the Industrial Peace Act, can issue an order requiring the deposit of a labor union’s financial records with the court without first conducting a hearing for the union officials charged.

RULING

The Supreme Court denied the petition and upheld the order of the CIR. The Court ruled that the CIR acted within its statutory authority. Section 17 of the Industrial Peace Act grants the CIR the power to investigate complaints regarding violations of internal labor organization procedures, such as the alleged financial mismanagement and refusal to render accounting in this case. The law implicitly provides the CIR with the necessary ancillary powers to effectively conduct such investigations, including the authority to secure and preserve vital financial records as evidence. The order was a valid exercise of this investigative power to prevent the possible concealment or dissipation of evidence pending the hearing.
On the due process challenge, the Court held that no denial of procedural due process occurred. While the initial order was issued ex parte, petitioners were afforded a full opportunity to be heard when they filed and argued their motion for reconsideration before the CIR en banc. Jurisprudence establishes that due process is satisfied when a party subsequently obtains a hearing on a motion for reconsideration, curing any initial defect from the lack of a prior hearing. The essence of due process is fairness and the opportunity to be heard, which petitioners received. Therefore, the CIR’s resolution sustaining the order was legally sound. The preliminary injunction issued by the Supreme Court was dissolved.