PMI Colleges v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Private respondent Alejandro Galvan was hired by petitioner PMI Colleges as a contractual instructor. He was initially compensated for services rendered but subsequently stopped receiving payment for succeeding services. Galvan claimed unpaid wages for basic seaman course classes, shipyard and plant visits, and on-the-job training, as well as for his services as Acting Director. He submitted documentary evidence to support his claims, including class schedules, unpaid load details, and vouchers prepared by petitioner's accounting department but not paid to him. Procedural History: Galvan filed a complaint for unpaid wages. Petitioner resisted, alleging that the classes were not held on school premises, that it lacked supervision, that the claims were exaggerated, and that Galvan abandoned his work. Both parties submitted position papers. The Labor Arbiter declared the case submitted for decision, denying petitioner's request for a formal trial. The Labor Arbiter ruled in favor of Galvan, ordering PMI Colleges to pay unpaid wages and attorney's fees. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision in toto. The Petition: Petitioner PMI Colleges filed a petition for certiorari with the Supreme Court, assailing the NLRC resolution. It raised issues concerning the legal and factual bases of Galvan's money claims, the validity of claims for on-the-job training and shipboard visits, denial of procedural due process, and the legal and factual support for the NLRC's findings.
Issue(s)
Whether the money claims of private respondent representing salaries/wages as contractual instructor for class instruction, on-the-job training and shipboard and plant visits have valid legal and factual bases. Whether claims for salaries/wages for services relative to on-the-job training and shipboard and plant visits by instructors, assuming the same were really conducted, have valid bases. Whether the petitioner was denied its right to procedural due process. Whether the NLRC findings in its questioned resolution have sound legal and factual support.
Ruling
The petition is dismissed for lack of merit, and the resolution of the National Labor Relations Commission dated August 4, 1995, is affirmed.
Ratio Decidendi
On the issue of whether the money claims have valid legal and factual bases: The Court held that the absence of a written contract does not negate the existence of an employment relationship, as contracts are obligatory in whatever form they are entered into, provided essential requisites are present, and no specific form is required for employment contracts of this nature. The Court found that vouchers prepared by petitioner's accounting department and the letter-request from its Acting Director sufficiently supported the conclusion that private respondent was employed. Petitioner's assertion that the signatory was not authorized by its by-laws was deemed ineffective against third parties without knowledge of such by-laws, and petitioner failed to prove private respondent's knowledge thereof. The Court also noted that petitioner failed to present satisfactory proof to contradict the amounts demanded by private respondent, thus constraining reliance on the latter's straightforward explanation. On the issue of the validity of claims for on-the-job training and shipboard visits: The Court found that the Labor Arbiter and NLRC accorded due weight to documents prepared by private respondent, which were not rendered self-serving merely because they were prepared by him. Ample opportunity was given to petitioner to rebut their veracity and authenticity, which it failed to do effectively, opting instead for mere denial. The Court found petitioner's denial to be what is considered self-serving evidence, deserving scant consideration. The affirmative and detailed manner by which private respondent supported his claims, including places and duration of services, was not effectively refuted by petitioner. On the issue of denial of procedural due process: The Court ruled that the absence of a formal hearing was not a cause for imputing grave abuse of discretion, as the decision to conduct one rests solely with the Labor Arbiter, considering the submitted position papers and documents. The Labor Arbiter was confident in relying on the documents presented, which adequately established private respondent's employment, the nature of his services, and the amounts due. Petitioner failed to controvert these facts and did not attach its supporting evidence with its position paper, thus it could not insist on a trial to ventilate what should have been done earlier. The Court cited NLRC rules requiring parties to submit all supporting documents with their position papers, precluding them from alleging or presenting evidence on facts not referred to therein. On the issue of whether the NLRC findings have sound legal and factual support: The Court reiterated that its certiorari jurisdiction is limited to reviewing jurisdictional issues and grave abuse of discretion, not the correctness of evidence evaluation. The Court found no palpable mistake or complete disregard of evidence by the NLRC. Petitioner failed to establish that the NLRC acted capriciously and whimsically. The Court emphasized that it is not a trier of facts and that factual issues are not proper subjects for certiorari. The Court concluded that the NLRC's findings were supported by substantial evidence on record, and petitioner failed to demonstrate any grave abuse of discretion amounting to lack or excess of jurisdiction.
Main Doctrine
The Supreme Court, in a petition for certiorari under Rule 65, is limited to reviewing jurisdictional issues and grave abuse of discretion, and does not ordinarily pass upon the correctness of the evaluation of evidence by lower tribunals. Factual issues are not proper subjects for certiorari. The essence of due process is a reasonable opportunity to be heard and to submit evidence, which is satisfied even without a formal trial if parties are given the chance to submit position papers and supporting documents.