Scenarios v. Vinluan
REITERATIONFacts
The Antecedents: Jelly Vinluan (Respondent), a former setman of Scenarios, Inc., filed a complaint for illegal dismissal, underpayment of salaries, and non-payment of benefits against Scenarios, Inc., Rhotziv Bago (Petitioners), and a certain Jess Jimenez on August 8, 2000. Summons were sent by registered mail to Jess Jimenez at the business address of Scenarios, Inc. However, the envelope was returned to the sender marked as 'UNCLAIMED,' with notations indicating that a second notice was sent on August 14 and a last notice on September 6. Procedural History: Due to the petitioners' failure to appear at scheduled hearings, the Labor Arbiter (LA) deemed their right to file a position paper waived. On April 26, 2001, the LA rendered a decision ordering the reinstatement of Vinluan with full backwages. Petitioners claimed they only became aware of the case when a writ of execution was served on July 6, 2001. They appealed to the National Labor Relations Commission (NLRC), which initially remanded the case for proper service. However, the Court of Appeals (CA) reversed the NLRC, ruling that petitioners failed to overcome the presumption of regularity of service and that their appeal was filed beyond the ten-day reglementary period. The Petition: Petitioners filed a petition for review on certiorari under Rule 45, arguing that they were denied due process. They contended that Jess Jimenez was a 'complete stranger' to the corporation, rendering the service of summons invalid. They further maintained that there was no competent proof that the notices of hearing or the LA's decision were actually delivered to or received by authorized officers of Scenarios, Inc.
Issue(s)
Whether the petitioners were denied due process due to the alleged invalidity of the service of summons and notices of hearing.
Ruling
The petition is DENIED. The Decision and Resolution of the Court of Appeals are AFFIRMED.
Ratio Decidendi
On Issue 1: The Supreme Court held that the service of summons and notices was valid and complete pursuant to Sections 5 and 6, Rule III of the New National Labor Relations Commission (NLRC) Rules of Procedure. The Court emphasized that service by registered mail is deemed complete five (5) days after the first notice from the postmaster if the addressee fails to claim the mail. In this case, the summons envelope bore notations of multiple notices and was marked 'UNCLAIMED,' which constitutes prima facie proof of the facts indicated therein. The Court applied the presumption of regularity in the performance of official duty, noting that it was incumbent upon the petitioners to rebut this presumption with competent evidence, which they failed to do. Regarding the argument that Jess Jimenez was a stranger, the Court noted that the business name and address were correctly indicated on the envelope, and the Labor Arbiter could reasonably rely on the information provided in the complaint. Furthermore, postal certifications confirmed that subsequent notices and the decision itself were delivered to the petitioners' business address and received by personnel on the premises. Consequently, the petitioners' appeal to the NLRC, filed nearly two months after the deemed receipt of the decision, was correctly declared late, as technical rules are relaxed in quasi-judicial proceedings in favor of substantial compliance with due process.
Main Doctrine
Under the New National Labor Relations Commission (NLRC) Rules of Procedure, specifically Rule III, Section 6, the return of the registered mail as 'unclaimed' is prima facie proof of the facts indicated therein. Service is deemed complete five (5) days after the first notice from the postmaster if the addressee fails to claim the mail. This rule ensures that parties cannot frustrate the ends of justice by simply refusing to claim their mail, and it is supported by the legal presumption that official duty has been regularly performed by postal authorities.