GR 78212; (January, 1990) (Digest)
G.R. No. 78212 ; January 22, 1990
T.H. VALDERAMA & SONS, INC. and/or ROBERTO TINSAY, petitioners, vs. HON. FRANKLIN DRILON, DANNY GONZAGA and 276 OTHER WORKERS, respondents.
FACTS
The case originated from a complaint filed by Danny Gonzaga on behalf of 276 employees against their employer, T.H. Valderama & Sons, Inc., for non-payment and underpayment of wages, emergency cost of living allowance (ECOLA), and 13th month pay. Labor Standards Enforcement Unit officers conducted an inspection at the company premises. After being informed the manager was unavailable on two visits, the officers proceeded with their investigation. Their report found violations, including the failure to keep employment records on-site and underpayment of benefits. Based on this, the Assistant Regional Director issued a Compliance Order directing the company to pay approximately P1.9 million.
The company later filed a motion for reconsideration, submitting pay slips and daily time records, which led to a recomputation reducing the liability to about P1.49 million. A summary investigation was scheduled, but the petitioners failed to appear. The Regional Director subsequently issued a writ of execution. The company appealed to the Minister of Labor, who affirmed the modified order. A subsequent motion for reconsideration to Secretary Franklin Drilon was denied, prompting this petition for certiorari.
ISSUE
Whether the petitioners were denied their right to procedural due process in the administrative proceedings before the Department of Labor and Employment.
RULING
The Supreme Court ruled that the petitioners were not denied procedural due process. The Court emphasized that while due process is essential in quasi-judicial proceedings, the standard in administrative cases is more flexible, requiring only fairness and justice. The record revealed that petitioners had multiple opportunities to present their defense but were negligent. They failed to appear at the initial hearing scheduled after the inspection report and again at a subsequent summary investigation, despite alleged notices.
Crucially, the petitioners were able to actively participate by submitting evidence (pay slips and daily time records) that directly resulted in a significant reduction of the monetary award. Furthermore, they exercised their right to appeal the Compliance Order and writ of execution to the Minister of Labor and later filed a motion for reconsideration with the Secretary of Labor. The Court cited established doctrine that the opportunity to be heard on a motion for reconsideration can cure any prior procedural irregularity. Therefore, having availed themselves of these remedial avenues, the petitioners cannot successfully claim a denial of due process. The petition was dismissed for lack of merit.