GR 88683; (October, 1990) (Digest)
G.R. No. 88683 October 18, 1990
RAPID MANPOWER CONSULTANTS, INC., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, DAVID PRODIGALIDAD, FERNANDO DABU, WILFREDO NAZARENO AND DANTE SAN MIGUEL, respondents.
FACTS
Petitioner Rapid Manpower Consultants, Inc., on behalf of its foreign principal, hired private respondents as janitors for deployment to Saudi Arabia. Before their contracts expired, the workers were repatriated to the Philippines allegedly for violations of company rules and Saudi law. Consequently, they filed a complaint with the Philippine Overseas Employment Administration (POEA) for illegal dismissal and monetary claims including overtime pay and salary differential. The POEA ruled in favor of the workers, awarding them monetary benefits and attorney’s fees.
Petitioner appealed to the National Labor Relations Commission (NLRC), raising as its sole assignment of error that the POEA administrator erred in appreciating the facts leading to the dismissal. Later, petitioner filed a Supplemental Memorandum, moving for a new trial based on newly discovered employment records from Saudi Arabia which it claimed would justify the dismissals. The NLRC affirmed the POEA’s monetary awards but remanded only the issue of illegal dismissal for further reception of evidence, holding that the monetary claims were not appealed.
ISSUE
Whether the NLRC erred in not remanding the entire case, including the issues of overtime pay and salary differential, to the POEA for further reception of evidence.
RULING
Yes, the Supreme Court reversed the NLRC and ordered the remand of the entire case. The Court emphasized that technical rules of procedure are not strictly applied in labor cases, and the paramount concern is substantial justice. While petitioner’s appeal specifically cited an error only on the issue of dismissal, its prayer in the original Memorandum on Appeal sought a complete reversal of the POEA decision. This comprehensive prayer necessarily encompassed all issues decided against it, including the monetary awards.
The legal logic rests on due process and equitable considerations. Petitioner had promptly manifested before the POEA its lack of evidence and need for time to secure documents from Saudi Arabia, a request not granted. The newly discovered evidence from the foreign employer pertains not only to the validity of the dismissal but also to the factual basis of the money claims, such as hours worked and rates paid. To allow a piecemeal remand would be contrary to the Labor Code’s directive to use all reasonable means to ascertain facts speedily and objectively. Fair play dictates that all evidence be considered in one proceeding to fully resolve the rights and obligations of both parties, preventing a multiplicity of suits and ensuring a complete and just resolution.