GR L 49481; (October, 1979) (Digest)
G.R. No. L-49481 October 23, 1979
GAS CORPORATION OF THE PHILIPPINES, petitioner, vs. THE HONORABLE ACTING MINISTER OF LABOR AMADO G. INCIONG, et al., respondents.
FACTS
Petitioner Gas Corporation of the Philippines (GASCOR) sought to terminate the employment of private respondents Jesus Valdez and Fernando Santos. The Labor Arbiter, however, denied GASCOR’s application for clearance to terminate and instead ordered the reinstatement of the employees. GASCOR appealed to the National Labor Relations Commission (NLRC) and subsequently to the Acting Minister of Labor, but both affirmed the Labor Arbiter’s decision. GASCOR then filed this certiorari and prohibition proceeding, alleging a denial of procedural due process. It contended that the Labor Arbiter rendered a decision in favor of Fernando Santos without Santos having submitted any position paper, document, or witnesses, thereby depriving GASCOR of its day in court and the opportunity to present evidence and cross-examine Santos.
ISSUE
Whether the Labor Arbiter and the public respondents denied GASCOR its right to procedural due process in the proceedings leading to the reinstatement of the private respondents.
RULING
The Supreme Court dismissed the petition, ruling that no denial of procedural due process occurred. The Court, referencing the standards set in Ang Tibay v. Court of Industrial Relations, acknowledged that administrative tribunals must satisfy due process but are allowed a certain latitude provided fairness is not ignored. The record contradicted GASCOR’s claim. Fernando Santos had in fact submitted an affidavit with annexes during a scheduled hearing, which constituted his evidence. GASCOR itself had submitted its position paper with supporting documents. Therefore, both parties were afforded the opportunity to present their respective evidence.
The Court further held that GASCOR’s inability to present its evidence or cross-examine Santos was not due to any procedural defect but to its own failure to avail itself of the opportunities provided. The case was scheduled for multiple hearings, and GASCOR could have presented its evidence irrespective of whether Santos presented his. Moreover, GASCOR had the chance to cross-examine Santos when he submitted his affidavit and during subsequent hearings; by not doing so, it waived that right. Fundamentally, the reinstatement was a direct consequence of GASCOR’s failure to substantiate its application for termination by proving a legal or just cause for dismissal. The burden of proof in termination cases lies with the employer. Since GASCOR did not meet this burden, the employees were entitled to reinstatement regardless of the extent of their own evidence presentation. The decision of the Acting Minister of Labor was thus affirmed.