GR 95711; (April, 1995) (Digest)
G.R. No. 95711 , April 21, 1995
CITY FAIR CORPORATION, represented by its Manager PATROCINIA G. MANALASTAS, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION (FOURTH DIVISION), JOCELYN ESCABILLAS, LILIAN WENCESLAO, et al., respondents.
FACTS
Private respondents were sales employees of petitioner City Fair Corporation in Ormoc City. In May 1989, they were served termination papers for retrenchment. When settlement efforts failed, they staged a strike on June 10, 1989. Petitioner filed a complaint for illegal strike. The private respondents and their union, LEFILDO, filed separate cases for unfair labor practice and illegal dismissal. The Labor Arbiter consolidated the cases and ultimately declared the strike illegal, ordering the termination of the employees and holding them jointly and severally liable to pay petitioner P820,000.00 and to LEFILDO P42,000.00 as damages.
On appeal, the National Labor Relations Commission (NLRC) modified the Labor Arbiter’s decision by deleting the awards of damages to both City Fair and LEFILDO for lack of factual and legal basis. The NLRC also entertained the appeal despite it being filed one day late, applying the principle of liberality. Petitioner moved for reconsideration, which was denied, prompting this petition for review.
ISSUE
Whether the NLRC committed grave abuse of discretion in deleting the award of damages and in entertaining the appeal filed one day late.
RULING
The Supreme Court dismissed the petition, finding no grave abuse of discretion by the NLRC. On the deletion of damages, the Court held that the alleged losses suffered by the petitioner due to the strike were never substantially proved. The only evidence presented was an unsigned summary of losses certified by a CPA, which was deemed insufficient, especially given the large amount awarded. More convincing evidence was required to justify such an award.
On the procedural issue, the Court ruled that the NLRC did not commit grave abuse of discretion in entertaining the appeal despite its tardiness. Proceedings before labor agencies need not adhere strictly to technicalities, as emphasized under Articles 218(c) and 221 of the Labor Code, which prioritize substantive justice. The Court has previously allowed appeals filed beyond the reglementary period in the interest of justice, particularly when weighing the conflicting interests of labor and capital with sympathy for the underprivileged worker. Considering that the private respondents were salesgirls seeking better working benefits, a greater injustice would occur if their appeal were not heard. Thus, the NLRC’s actions were justified.