G.R. No. L-5621 March 25, 1953
PHILIPPINE MOVIE PICTURES WORKERS’ ASSOCIATION, petitioner, vs. PREMIERE PRODUCTIONS, INC., respondent.

FACTS

On October 2, 1951, respondent Premiere Productions, Inc. filed an urgent petition with the Court of Industrial Relations (CIR) seeking authority to lay off 44 employees from three departments, alleging financial losses and lack of work. The petitioner, Philippine Movie Pictures Workers’ Association, opposed the petition, claiming the alleged financial losses were baseless and that the lay-off was an act of retaliation for a previous strike. On November 5, 1951, at the hearing, the presiding judge, Hon. Arsenio C. Roldan, conducted an ocular inspection of respondent’s studios at respondent’s counsel’s request. During the inspection, the judge interrogated about fifteen laborers and examined some company records, including time cards. Based on this ocular inspection, Judge Roldan issued orders on November 8 and November 24, 1951, authorizing the lay-off, subject to conditions of re-employment and potential back pay. The petitioner’s motion for reconsideration was denied by the CIR en banc on March 10, 1952.

ISSUE

May the Court of Industrial Relations authorize the lay-off of workers based solely on an ocular inspection without receiving full evidence to determine the cause or motive of such lay-off?

RULING

No. The Supreme Court set aside the CIR orders and remanded the case for further proceedings. While the CIR may adopt its own procedural rules and is not bound by technical rules of evidence under Section 20 of Commonwealth Act No. 103 , it cannot disregard the fundamental requirements of due process. The right to labor is a constitutional and statutory right, and a person cannot be deprived of work without due process of law. An ocular inspection is merely an auxiliary remedy to help the court reach a determination; it is not a substitute for a full hearing where parties can present evidence and cross-examine witnesses. The allegations of lack of work and financial losses, central to the lay-off petition, could not be conclusively established by a mere ocular inspection, especially one conducted at the request of the interested party. The Supreme Court found that the required due process was not followed, as the petitioner was not given a full opportunity to present evidence to disprove the respondent’s claims. The Court resolved doubts in favor of labor, in line with the constitutional spirit of protection.