G.R. No. 80500 July 5, 1989
ROBUSTA AGRO MARINE PRODUCTS, INC. and MARIO SANTOS, JR., petitioners, vs. BALTAZAR GOROMBALEM, NATIONAL LABOR RELATIONS COMMISSION (NLRC), Second Division, DEPARTMENT OF LABOR AND EMPLOYMENT, Manila, and VICENTE MANZANO, Labor Arbiter, NLRC, Arbitration Branch, Region IV, respondents.

FACTS

Private respondent Baltazar Gorombalem filed a complaint against petitioner Robusta Agro Marine Products, Inc. for illegal dismissal and various monetary claims. After several reset hearings aimed at amicable settlement failed, the labor arbiter directed the parties to submit their position papers. Gorombalem filed his sworn statement. Robusta, after being granted three extensions, filed a fourth motion for extension, which was denied. The labor arbiter instead gave Robusta a final three-day period to file its position paper, warning that the case would be decided based on the submitted documents thereafter. Robusta submitted a position paper, but reserved its right to file a supplemental paper. The labor arbiter subsequently rendered a decision based solely on the position papers, ordering reinstatement and payment of monetary awards to Gorombalem. Robusta appealed to the NLRC, arguing it was denied administrative due process because no formal trial was conducted. The NLRC affirmed the arbiter’s decision, prompting Robusta to elevate the case to the Supreme Court via a petition for certiorari.

ISSUE

Whether the labor arbiter denied petitioners administrative due process by rendering a decision based on position papers without conducting a formal trial or hearing.

RULING

The Supreme Court dismissed the petition, ruling that no denial of administrative due process occurred. The essence of due process in administrative proceedings is the opportunity to be heard and to submit evidence in one’s defense. The Court emphasized that labor proceedings are not bound by the technical rules of evidence and procedure observed in regular courts. Under Article 221 of the Labor Code, labor arbiters are empowered to decide cases based on position papers and submitted documents to ensure speedy labor justice. The records showed Robusta was given ample opportunity to present its case; it was granted multiple extensions and ultimately filed its position paper. At no point did Robusta formally request a trial or hearing. The labor arbiter, within his discretion, determined that a hearing was unnecessary as the issues could be resolved based on the pleadings. The Court also noted Robusta’s inconsistent defenses—initially claiming voluntary resignation, then later suggesting the dismissal was justified—which undermined its position. Therefore, petitioners were afforded their right to be heard and were not deprived of due process.