GR 81374; (April, 1991) (Digest)
G.R. No. 81374 ; April 30, 1991
JOSE R. BAUTISTA, SEVERINO GABUYO and NORTH EASTERN COLLEGE, INC., petitioners vs. HON. SECRETARY OF LABOR AND EMPLOYMENT, et al., respondents.
FACTS
The private respondents, janitors at North Eastern College, Inc., filed a complaint on December 15, 1984, against the school and its officers (petitioners) for illegal wage deductions under Articles 113 and 116 of the Labor Code. After investigation, the Assistant Regional Director found the deductions illegal but disallowed reimbursement, holding the deductions were used to pay the workers’ personal obligations. The complainants appealed to the Ministry of Labor, claiming they had settled these obligations. On January 6, 1986, the Deputy Minister affirmed the illegality and ordered the petitioners to reimburse the deducted amounts.
A Writ of Execution was later issued, followed by an Alias Writ on December 7, 1987, specifying the exact amounts due to each worker. The petitioners then filed an Exception to the Alias Writ, contending it was void as it proceeded from an order issued pursuant to an appeal filed out of time and without notice to them. The Regional Office dismissed their exception, leading to the seizure of office equipment by the sheriff to satisfy the judgment.
ISSUE
Whether the petitioners were denied due process in the administrative proceedings before the Department of Labor and Employment.
RULING
The Supreme Court ruled that the petitioners were not denied due process. The essence of due process in administrative proceedings is an opportunity to be heard, which was afforded. The record showed the complaint was validly served at the office of petitioner Jose R. Bautista, received by his Executive Assistant, a person in charge, constituting proper service under suppletory rules. Furthermore, the petitioners were furnished a copy of the Deputy Minister’s Order and the letter-appeal, evidenced by registry receipts.
The Court emphasized that administrative tribunals exercising quasi-judicial functions are not bound by the rigid technicalities of court procedure, as long as fundamental fairness is observed. The lack of a formal hearing does not equate to a denial of due process; the opportunity to explain one’s side or seek reconsideration suffices. The petitioners’ invocation of due process was deemed an afterthought, raised only after the substantial liability was quantified. Due process is for the vigilant, not for those who, having the right to be heard, choose inaction. The challenged orders were validly promulgated.