G.R. No. L-63284 April 4, 1984
SAULOG TRANSIT, INC., petitioner, vs. HON. MANUEL M. LAZARO, in his capacity as Presidential Assistant for Legal Affairs, HON. BLAS F. OPLE, Minister of Labor and Employment, and ROBERT AREVALO, respondents.

FACTS

On January 23, 1981, employees of Saulog Transit, Inc. staged a strike. The Minister of Labor issued immediate return-to-work orders, directing workers to return and management to accept them under pre-strike terms. Subsequent conciliation failed, leading the Minister to assume jurisdiction and submit the dispute for compulsory arbitration. The union, through respondent Robert Arevalo, filed a position paper. Saulog Transit filed an omnibus motion to dismiss, challenging the jurisdiction of the Ministry, the propriety of the class suit, and the lack of a formal complaint.
The Minister of Labor issued a resolution on April 1, 1981, ordering Saulog Transit to upgrade driver and conductor commissions, pay 13th month pay and statutory allowances to qualified employees, and share bus cleaning responsibilities. Upon reconsideration, the Minister discovered a Supplemental Collective Bargaining Agreement providing for higher wage rates, which management had not disclosed. The January 20, 1982 decision thus modified the order, compelling compliance with this agreement. Saulog Transit’s appeal to the Office of the President was denied, prompting this certiorari petition alleging denial of due process and procedural errors.

ISSUE

Whether the public respondents committed grave abuse of discretion or denied due process in issuing the assailed orders.

RULING

The Supreme Court dismissed the petition, affirming the decisions of the public respondents. The Court held that no denial of due process occurred. Saulog Transit was afforded ample opportunity to be heard through its participation in conciliation conferences, the submission of its position paper (incorporated in its omnibus motion), and its motions for reconsideration before both the Ministry of Labor and the Office of the President. Due process in administrative proceedings does not require strict adherence to judicial technicalities; it is satisfied by a fair and reasonable opportunity to explain one’s side.
The Court emphasized that proceedings before the Ministry of Labor are summary and not governed by technical rules of procedure, as provided under Article 221 of the Labor Code. The core findings and orders—including payment of the 13th month pay, statutory allowances, and enforcement of the Supplemental Collective Bargaining Agreement—were substantively correct and in line with constitutional mandates for social justice and labor protection. Petitioner’s reliance on purely procedural grounds, without demonstrating a denial of substantial justice or grave abuse of discretion, was insufficient to overturn the administrative decisions. The return-to-work orders and the consequences for non-compliance were likewise upheld as valid exercises of the Minister’s compulsory arbitration power.