G.R. No. 74412, June 13, 1990
SKILLWORD MANAGEMENT AND MARKETING CORPORATION, SHARY LIMOUSINE, MR. SERAFIN RAMOS AND MRS. ALICIA RAMOS, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION AND FRANCISCO R. MANUEL, respondents.

FACTS

Petitioner Skillworld Management and Marketing, operated by spouses Serafin and Alicia Ramos, deployed respondent Francisco R. Manuel to Saudi Arabia on June 24, 1983, to work as a driver for petitioner Shary Limousine under a two-year contract. On August 24, 1983, Manuel was repatriated. He alleged his dismissal was illegal, claiming he was made to drive with invalid documents presented by his employer as a temporary license, leading to his repatriation after he and other drivers raised the issue. Upon his return, the petitioners promised redeployment, which did not materialize.
Manuel filed an illegal dismissal complaint with the Philippine Overseas Employment Administration (POEA). The petitioners countered that his dismissal was for just causes, including disobedience and engaging in concerted activities, supported by affidavits from the foreign employer’s personnel. The POEA ruled in favor of Manuel, awarding him salary for the unexpired portion of his contract. The National Labor Relations Commission (NLRC) affirmed the decision. Petitioners subsequently filed a petition for relief from judgment with the POEA, raising for the first time a new defense regarding Saudi Arabian law on driving authority, which the POEA denied.

ISSUE

Whether the NLRC committed grave abuse of discretion in affirming the POEA’s decision and in not remanding the case for a rehearing to consider the petitioners’ newly raised defense.

RULING

The Supreme Court dismissed the petition, finding no grave abuse of discretion. The legal logic centers on procedural due process and the proper stage for raising defenses. The petitioners’ new defense regarding Saudi Arabian law was not alleged in their answer before the POEA nor raised in their appeal to the NLRC. It was introduced only in a petition for relief from judgment filed well after the NLRC’s decision. The Court deemed this an afterthought, noting the defense was available and could have been presented during the original proceedings or on appeal.
While technical rules are generally not binding in labor cases under Article 221 of the Labor Code, this flexibility is intended to ascertain facts speedily without regard to technicalities, not to permit parties to change their theory of the case at a late stage after facts have been established. Allowing a remand for a rehearing based on this belated defense would unduly delay the termination of the case, prejudicing the respondent’s right to a speedy resolution. The Court found that the petitioners were afforded full opportunity to be heard and present evidence; their counsel’s alleged failure to raise the defense earlier did not constitute excusable neglect warranting relief. Thus, the denial of the petition for relief and the affirmance of the illegal dismissal ruling were proper.