G.R. No. L-65045 July 20, 1990
ARTEX DEVELOPMENT CO., INC., petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, NORIEL GONZALES and CLARITA BENSON, respondents.

FACTS

Petitioner Artex Development Co., Inc. dismissed private respondents Noriel Gonzales and Clarita Benson. Gonzales was terminated for alleged abandonment and gambling without being given a chance to refute the charges. Benson was laid off during a temporary shutdown but later received a termination letter for abandonment. They filed complaints for illegal dismissal. The Labor Arbiter scheduled multiple hearings, with notices sent to the company via telegram. The company’s representative failed to appear at any hearing, prompting the complainants to move for submission of the case for decision. Only the private respondents submitted their position paper.
Consequently, the Labor Arbiter rendered a decision in favor of the complainants, ordering their reinstatement with full backwages, due to the company’s failure to appear and present evidence. The company filed a motion for reconsideration, claiming it never received any summons or notices, and later appealed to the NLRC, alleging denial of due process. The NLRC dismissed the appeal, finding that telegrams confirming the notices were sent, and the company’s failure to avail itself of the hearings constituted a waiver of its right to present evidence.

ISSUE

Whether the National Labor Relations Commission committed grave abuse of discretion in affirming the Labor Arbiter’s decision, thereby denying the petitioner due process of law.

RULING

The Supreme Court denied the petition, finding no merit in the due process claim. The legal logic rests on the presumption of regularity in the sending of notices and the essence of due process in administrative proceedings. The confirmation copies of the telegraphed notices established that they were properly sent and delivered. Given that the petitioner had not changed its address and had received other resolutions sent to the same address, the presumption arose that it received the hearing notices. The Court emphasized that due process in administrative bodies is satisfied by a reasonable opportunity to be heard. The petitioner was afforded this opportunity through the scheduled hearings, and its own failure to appear constituted a waiver.
Furthermore, the Court held that even if the petitioner was not heard during the initial fact-finding stage, it cannot claim absolute lack of due process because it was given the opportunity to present its side through its motions for reconsideration and its appeal to the NLRC, which were duly considered. The core of due process is the opportunity to be heard, not necessarily the receipt of previous notice. The factual findings of the NLRC, supported by substantial evidence like the telegram confirmations, are generally accorded finality. The Court modified the Labor Arbiter’s decision only by limiting the award of backwages to three years, in conformity with prevailing jurisprudence.