GR 37034; (January 1976) (Digest)
G.R. No. L-37034 January 30, 1976
JACQUELINE INDUSTRIES DUNHILL BAGS INDUSTRIES, POL YAP, CANDIDO DYONCO and HENRY YAP, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION and GAUDENCIA DE QUIROZ, respondents.
FACTS
Petitioners, Jacqueline Industries Dunhill Bags Industries and its officers, filed a motion for reconsideration or new trial following an adverse Supreme Court decision dated August 29, 1975, which dismissed their certiorari and prohibition suit and sustained the money claim of private respondent Gaudencia de Quiroz. They raised three grounds: first, a denial of due process due to an alleged absence of a hearing before the NLRC; second, the non-existence of an employer-employee relationship, claiming private respondent was dismissed and did not appeal; and third, a request for a hearing to prove the claim was barred by prescription or laches.
The National Labor Relations Commission and private respondent filed comments opposing the motion. The Solicitor General, representing the NLRC, submitted a detailed comment refuting each of petitioners’ arguments. The comment outlined the procedural steps taken, including fact-finding and mediation hearings conducted with prior notice to the parties, and addressed the substantive issues regarding the continuity of the employment relationship and the untimeliness of the prescription defense.
ISSUE
Whether the motion for reconsideration or new trial, based on the grounds of denial of due process, absence of employer-employee relationship, and prescription of the claim, should be granted.
RULING
The Supreme Court denied the motion for reconsideration and for new trial, affirming its August 29, 1975 decision. The Court found the motion devoid of merit, primarily relying on the NLRC’s well-reasoned comment. On the due process claim, the record showed that mediation and fact-finding hearings were conducted with notice; petitioners’ non-appearance was their own fault, and administrative proceedings are non-litigious and summary, not requiring strict judicial rules. Thus, petitioners were accorded every opportunity to be heard.
Regarding the employer-employee relationship, the Court upheld the NLRC’s finding that the relationship never ceased. Private respondent was on sick leave and was illegally dismissed upon her return; illegal dismissal does not sever the employment relationship for purposes of claims under labor laws. The NLRC had original and exclusive jurisdiction over such matters involving employer-employee relations under Presidential Decree No. 21. On prescription and laches, the defense was waived for not being pleaded in the answer before the NLRC, as defenses not raised in the answer are deemed waived. The Court concluded the decision was supported by law and a new trial would serve no useful purpose. The prior decision was ordered implemented forthwith.