GR L 49893; (May, 1988) (Digest)
G.R. No. L-49893 May 9, 1988
DANIEL C. ASPACIO, petitioner, vs. HON. AMADO INCIONG and PEPSI COLA BOTTLING COMPANY OF THE PHILIPPINES, respondents.
FACTS
Petitioner Daniel Aspacio, employed by Pepsi Cola Bottling Company, was retired due to malignant hypertension. He received partial retirement benefits and subsequently filed a complaint with the Department of Labor to recover an alleged balance of P7,535.62 in retirement benefits and unpaid sales commissions under the Collective Bargaining Agreement (CBA). The labor arbiter ruled in Aspacio’s favor, ordering Pepsi to pay both the balance and the commissions, the latter to be computed by a Socio-Economic Analyst.
Pepsi appealed to the National Labor Relations Commission (NLRC), which dismissed the appeal. Pepsi then elevated the case to the Secretary of Labor. During the pendency of this appeal, the labor arbiter issued a writ of execution for the P7,535.62, which was collected and released to Aspacio. However, the labor arbiter later ordered Aspacio to return the money due to a stay of execution from the Secretary of Labor.
ISSUE
The core issues were: (1) whether the Deputy Minister of Labor could validly reverse the labor arbiter’s factual findings regarding the claim for unpaid commissions, and (2) whether the Deputy Minister could entertain Pepsi’s appeal despite an alleged procedural defect concerning appeal fees.
RULING
The Supreme Court dismissed the petition, upholding the Deputy Minister’s decision. On the first issue, the Court ruled that the Deputy Minister acted within his authority. The labor arbiter’s award for unpaid commissions was not supported by substantial evidence. Aspacio failed to present clear and convincing proof specifying the amount due, the relevant period, or the sales made. The CBA provision indicated commissions were calculated periodically, not solely payable upon retirement. The burden of proof lies with the claimant, and Aspacio did not discharge this burden. Furthermore, a notarized release and quitclaim presented by Pepsi constituted a public document, implying all claims, including commissions, had been settled.
On the second issue, the Court found no merit in Aspacio’s procedural challenge. The applicable rules required the filing of an appeal within ten working days but did not mandate the payment of an appeal fee as a condition for perfection. Therefore, Pepsi’s appeal was properly entertained. The Court emphasized its role is not to re-evaluate facts but to apply the law based on the findings of administrative agencies, which were conclusive in this instance.