G.R. No. L-78936 January 7, 1988
Villa Rhecar Bus and/or Its Manager, petitioner, vs. Fructuoso De La Cruz and the Honorable National Labor Relations Commission, Second Division, respondents.

FACTS

Petitioner Villa Rhecar Bus, a transportation firm, employed private respondent Fructuoso De La Cruz as a line inspector from April 1979 until December 4, 1984. A dispute arose concerning De La Cruz’s separation pay, holiday pay, 13th month pay, and emergency living allowance, prompting him to file a complaint with the National Labor Relations Commission (NLRC). The case was assigned to Labor Arbiter Jose O. Libron.
During the proceedings, the parties, through their respective counsels, entered into an agreement to submit their position papers within 20 days from April 8, 1985, after which the case would be deemed submitted for resolution. Counsel for the petitioner, Atty. Ruben Pasamonte, failed to file the required position paper within the stipulated period. Consequently, the Labor Arbiter rendered a decision on March 13, 1986, in favor of De La Cruz, ruling that the petitioner had waived its right to present evidence.

ISSUE

Whether the Labor Arbiter and the NLRC committed grave abuse of discretion, amounting to lack or excess of jurisdiction, by deciding the case based solely on the complainant’s position paper, thereby allegedly violating the petitioner’s right to procedural due process.

RULING

The Supreme Court dismissed the petition for lack of merit. The Court held that no grave abuse of discretion was committed. The fundamental requirement of due process is the opportunity to be heard, not necessarily the guarantee of a favorable outcome. In this case, the petitioner was afforded this opportunity through its counsel of choice. The agreement to submit position papers within a set period was binding, and the failure of petitioner’s counsel to comply constituted a waiver of the right to present evidence.
Notice to counsel is considered notice to the client. The petitioner’s argument that the Labor Arbiter should have sent a separate notice directly to it is untenable, as it would undermine the established principles of agency and the rules governing the authority of attorneys to bind their clients in procedural matters. The negligence of counsel binds the client, and the general rule only admits exceptions in cases of serious injustice, which was not sufficiently demonstrated here. The proper recourse for the petitioner, if prejudiced by counsel’s negligence, is to pursue legal action against said counsel, not to assail the labor tribunals’ decisions which adhered to procedural rules.