Lawin Security Services, Inc. v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Lawin Security Services, Inc. (LAWIN) entered into a contract for security services with Allied Integrated Steel Corporation (ALLIED). Petitioners, security guards posted by LAWIN at ALLIED's premises, sought wage adjustments due to various decreed wage increases. These requests were not granted by ALLIED. Procedural History: The security guards filed a complaint before the Labor Arbiter. ALLIED questioned the Labor Arbiter's jurisdiction, asserting the absence of an employer-employee relationship and claiming the matter was cognizable by regular courts. The Labor Arbiter asserted jurisdiction, citing Sec. 5, par. B of the Rules Implementing Wage Order No. 6 and Arts. 107 and 109 of the Labor Code, and ordered ALLIED to pay wage adjustments. On appeal, the National Labor Relations Commission (NLRC) initially affirmed the Labor Arbiter's award but later set it aside and remanded the case to the Labor Arbiter for further proceedings upon ALLIED's motion for reconsideration. The NLRC found that the service of its resolution on ALLIED's counsel was improper, thus the period for filing a motion for reconsideration had not commenced. The NLRC also considered the merits of ALLIED's motion, emphasizing the interest of substantial justice. The Petition: Petitioners imputed grave abuse of discretion to the NLRC for favorably acting on ALLIED's motion for reconsideration, arguing that an entry of judgment had already occurred and that the evidence sought to be presented by ALLIED constituted forgotten evidence.
Issue(s)
Whether the National Labor Relations Commission committed grave abuse of discretion in entertaining respondent ALLIED's motion for reconsideration despite an alleged entry of judgment due to improper service. Whether the NLRC erred in remanding the case to the Labor Arbiter for further proceedings and admitting additional documentary evidence presented by respondent ALLIED on appeal, in the interest of substantial justice.
Ruling
The petition is DISMISSED. The Resolution of respondent National Labor Relations Commission of 26 September 1994 ordering the remand of the case to the Labor Arbiter for further proceedings as well as the Resolution of 28 November 1994 denying reconsideration is AFFIRMED.
Ratio Decidendi
On the issue of grave abuse of discretion and entry of judgment: The Court held that the NLRC did not commit grave abuse of discretion because the service of the NLRC's resolution on a security guard of the building where ALLIED's counsel had his office was deemed an invalid service. Consequently, the 10-day period for filing a motion for reconsideration had not commenced, and thus, there was no valid entry of judgment. The NLRC retained jurisdiction to entertain ALLIED's motion for reconsideration. The Court cited Section 4, Rule 13 of the Rules of Court, which mandates personal service or leaving the copy with a clerk or person in charge of the attorney's office, and emphasized that service on a building security guard is not legally effective. This invalid service meant the resolution did not become executory, preserving the NLRC's authority to act on the motion. On the issue of remanding the case and admitting additional evidence: The Court affirmed the NLRC's decision to remand the case and consider additional evidence in the interest of substantial justice. Article 221 of the Labor Code provides that technical rules of evidence are not binding in proceedings before the NLRC, and labor officials should use all reasonable means to ascertain facts speedily and objectively without regard to technicalities. The Court reiterated its stance in previous cases, such as Philippine Telegraph and Telephone Corporation v. NLRC, that technical rules should not impede the fair and complete resolution of labor disputes. The NLRC's action was justified by the need to correct potential injustices, especially considering ALLIED's claim, supported by evidence, that not all complainants were assigned to it or worked intermittently. The Court noted that it would be unjust to remain silent and refuse to correct itself when made aware of material facts that could change the original judgment, and that management also has rights that deserve respect.
Main Doctrine
Technical rules of procedure should not be allowed to stand in the way of equitably and completely resolving the rights and obligations of the parties, especially when substantial justice and the interest of due process are at stake. Labor tribunals are empowered to relax technicalities to ascertain facts speedily and objectively.