Petitioner

The New Valley Times Press, represented by Teodoro Bascos, Jr.

Respondents

National Labor Relations Commission and Jose Gorospe

Ponente

Medlaldea, J.

Docket Number and Date of Decision

G.R. No. 100482, July 15,1992

Significance of the Case

In this landmark case, the Supreme Court held that Labor officials should use every and reasonable means to ascertain the facts in each case speedily and objectively, without regard to technicalities of law or procedure, all in the interest of due process.

Facts

New Valley Times Press is a duly registered printing press located at Ilagan, Isabela, while Jose Gorospe is a linotype machine operator (linotypist) of petitioner.

Gorospe was first employed by the petitioner, then called Valley Times Press, as linotype machine operator in 1981. Sometime in 1983, he resigned. During this period, petitioner was operated and managed by the deceased parents of petitioner Teodoro Bascos, Jr.

Sometime in 1984, the owner-spouses lease the premises of the printing press and transfer its operation and management to Macario Evangelista. In 1986, Macario Evangelista re-hired Gorospe as linotypist.

Upon the expiration of the lease, the property was reverted back to the possession, management and control of the owner-spouses, who reorganized the business and gave it its present name, The New Valley Times Press.

Under this new set-up, the deceased Bascos re-hired some of the employees of Evangelista. However, Gorospe was not rehired because the deceased Bascos found out that the linotype machine previously being operated by him was not functioning properly.

This prompted Gorospe to institute a complaint against the printing press for illegal dismissal, non-payment of emergency cost of living allowance and moral damages.

The Labor Arbiter, in its decision, ordered the reinstatement of Gorospe with full backwages plus moral damages and attorney’s fees. On appeal, the Commission affirmed the decision of the labor arbiter but deleted the award of moral damages and attorney’s fees.

On motion for reconsideration of the decision of the Commission, the petitioner introduced for the first time contrary evidence to disprove the existence of employer-employee relationship.

The Commission denied the motion for reconsideration and refused to allow the introduction evidence at this late stage of the proceedings. It stressed that the rule of procedure does not allow new matters or incidents raised for the first time on appeal or on motion for reconsideration.

The petitioner insists that its inability to present evidence is fully justified because of the late Teodoro Bascos ill health which necessitated medical treatment abroad. Furthermore, his former counsel, who was then in his mid-eighties, is suffering from the debilitations of old age.

Petitioner also stresses that the failure of the present counsel to submit and present the pertinent documentary evidence from the outset of the appeal is justified because such documents were not yet known to him at that time and were in the custody of the late Bascos who was then undergoing medical treatment in the United States.

Issue

Whether or not the commission committed grave abuse of discretion in disallowing the introduction of evidence for the first time in the petitioner’s motion for reconsideration.

Ruling

The Commission gravely abused its discretion when it disallowed the presentation of petitioner’s evidence for the first time on motion for reconsideration.

The belated presentation of the evidence notwithstanding, respondent Commission should have considered them just the same. Labor officials should use every and reasonable means to ascertain the facts in each case speedily and objectively, without regard to technicalities of law or procedure, all in the interest of due process.

Thus, even assuming that the subject evidence were not submitted to the labor arbiter and later on appeal to the Commission, the fact that they were submitted on motion for reconsideration is cogent basis for the Commission to consider and admit the same, instead of falling back on the mere technicality that said evidence can no longer be considered and admitted on motion for reconsideration. Respondent Commission exercises quasi-judicial functions wherein the rules of technicality should give way to equity and fairness.

Last Edited: Sunday, March 20, 2011

Caveat: Subsequent court and administrative rulings, or changes to, or repeal of, laws, rules and regulations may have rendered the whole or part of this article inaccurate or obsolete.
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