Bristol Laboratories Employees' Association-DFA v. National Labor Relations Commission
REITERATIONFacts
1. The Antecedents: Rico G. Gata, employed as a Territory Manager by Bristol Laboratories (Phils.), Inc., was accused of unauthorized stock withdrawals from company customers. These withdrawals, totaling P25,603.60 from Farmacia Carillo and P16,527.50 from Dr. Gregorio de Guzman Medical Clinic, were allegedly made without proper authorization and were evidenced by bounced personal checks issued by Gata. Despite initial replacements of some payments, investigations by company management confirmed the unauthorized nature of the transactions, leading to Gata's dismissal for serious misconduct and wilful breach of trust. 2. Procedural History: Following his dismissal on April 29, 1987, Rico G. Gata, along with the Bristol Laboratories Employees' Association-DFA, filed a complaint for illegal dismissal and other related claims with the Ministry of Labor and Employment. After five hearings, the Labor Arbiter rendered a decision on July 28, 1988, dismissing the complaint for lack of merit but ordering the company to pay Gata separation pay. The petitioners appealed this decision to the National Labor Relations Commission (NLRC). The NLRC, on March 7, 1989, issued a resolution setting aside the Labor Arbiter's decision and remanding the case for further reception of evidence. A subsequent motion for reconsideration was denied by the NLRC on April 10, 1989. 3. The Petition: The petitioners, Bristol Laboratories Employees' Association-DFA and Rico G. Gata, filed this special civil action for certiorari and mandamus to assail the NLRC's resolutions. They contend that the NLRC gravely abused its discretion by considering unverified opposition and new evidence submitted by the respondent on appeal, and by remanding the case instead of resolving it on the merits. The petitioners argue that the NLRC should have ruled on the appeal based on the existing records, asserting that the Labor Arbiter's findings of lawful cause and due process were supported by substantial evidence.
Issue(s)
Whether the NLRC committed grave abuse of discretion in considering unverified opposition with evidence introduced for the first time on appeal, and whether it erred in remanding the case instead of resolving it on the merits. Whether the dismissal of petitioner Gata was for justifiable cause and with due process.
Ruling
The petition is granted. The Resolution of the NLRC remanding the case to the labor arbiter for further proceedings is set aside. The labor arbiter's decision dismissing the complaint is affirmed.
Ratio Decidendi
On the NLRC's consideration of additional evidence and remand: The Court held that no grave abuse of discretion may be attributed to the NLRC for having considered additional documentary evidence submitted by the respondent-employer on appeal. Procedural technicalities do not strictly apply to proceedings before labor arbiters. The Court noted that even if the additional evidence were disregarded, the evidence already on record was sufficient to support the Labor Arbiter's finding of legal and justifiable grounds for termination. Therefore, it was an error for the NLRC to remand the case when it could have resolved the appeal on the merits. On the merits of the dismissal: The Court affirmed the Labor Arbiter's findings that petitioner Gata was dismissed for justifiable causes and was afforded due process. Gata was charged with unauthorized stock withdrawals, a breach of trust. The Court also found that Gata was afforded due process, having been issued a memorandum to explain his side and subjected to an investigation. The Labor Arbiter's award of separation pay was deemed erroneous because an employee dismissed for cause is not entitled to such benefit, but since the employer did not appeal this part of the decision, it could not seek affirmative relief.
Main Doctrine
The National Labor Relations Commission (NLRC) may consider additional documentary evidence submitted by an employer on appeal, even if not presented before the Labor Arbiter, in line with the directive to ascertain facts with all reasonable means. However, if the evidence is merely cumulative and sufficient evidence already exists to support the Labor Arbiter's findings, the NLRC should resolve the appeal on the merits rather than remanding the case.