IRIGA TELEPHONE CO., INC., PETITIONER, VS. NATIONAL LABOR RELATIONS COMMISSION, HONORABLE DOMINADOR MEDROSO, JR. AND INOCENCIO PRAXIDES, RESPONDENT.

Iriga Telephone versus National Labor Relations Commission

The Case

This is a petition for certiorari under Rule 65 of the Rules of Court filed by Iriga Telephone Company, known as ITELCO, against the National Labor Relations Commission, Labor Arbiter Dominador Medroso, Junior, and its former employee Inocencio Praxides. ITELCO asks the Supreme Court to reverse the Commission's resolution ordering it to pay Praxides separation pay equivalent to one month pay for every year of service. The case matters for two reasons: it teaches when a labor arbiter may decide a case without a formal hearing, and it fixes the quantum of evidence and the measure of separation pay when reinstatement is no longer feasible.

Procedural History

Praxides filed a complaint before the National Labor Relations Commission Sub-Regional Arbitration Branch in Naga City, for unfair labor practice, underpayment, premium pay for holiday and rest day, and damages. He later amended it to include illegal dismissal, separation pay, and reinstatement. The case was assigned to Labor Arbiter Dominador Medroso, Junior. After several postponements at ITELCO's instance, the arbiter denied ITELCO's last motion, deemed the case submitted for decision, and rendered judgment dismissing the complaint for illegal dismissal and unfair labor practice for lack of merit, but ordering reinstatement without loss of seniority rights and without backwages, and, if reinstatement was no longer feasible, separation pay of one half month pay for every year of service plus labor standard benefits. Both parties appealed to the National Labor Relations Commission, which affirmed the arbiter's decision but increased the separation pay to one month pay for every year of service. ITELCO's motion for reconsideration was denied, so ITELCO elevated the case to the Supreme Court by petition for certiorari under Rule 65.

Facts

Inocencio Praxides was employed by Iriga Telephone Company as a collector-technician in 1974. On March 21, 1989, he complained to the secretary of the company president that the entries on his income tax return, Form 1701-B, were incorrect, because the salaries and bonuses reflected there were larger than what he had actually received in 1988. He was told to report the matter to the president and general manager, Attorney Santiago Ortega.

On April 1, 1989, a telephone operator handed Praxides a note from Attorney Ortega directing him to confer at four o'clock that afternoon. At the conference they discussed his complaints, including the disparity between his salary increase and that of his junior co-employees. Sensing that Attorney Ortega was losing his temper, Praxides prepared to leave, but Attorney Ortega called in a security guard, closed the door, kicked Praxides, subjected him to verbal abuse, and told him he was being terminated because of his propensity to complain. Praxides reported the incident to the Iriga Police Station and then went to St. Jude Hospital for treatment. He later filed a criminal complaint against Attorney Ortega, who was acquitted for insufficiency of evidence.

On April 3, 1989, Praxides wrote that he could not yet report for work until their differences were resolved, for fear of a repetition of the incident. Attorney Ortega denied the incident, declared Praxides out of his mind, and treated him as absent without leave. Praxides then filed his labor complaint. The hearings were reset repeatedly, and after the arbiter warned that no further postponements would be entertained, ITELCO sought another postponement. The arbiter denied it and deemed the case submitted for decision.

Issues

• Whether or not the National Labor Relations Commission acted with grave abuse of discretion amounting to lack of jurisdiction in affirming the labor arbiter's decision to decide the case without a formal hearing, despite ITELCO's insistence on one and without an order stating that no further hearing was necessary.
• Whether or not the National Labor Relations Commission acted with grave abuse of discretion in increasing the separation pay from one half month to one month salary for every year of service, despite the finding that Praxides went absent without leave.

Applicable Provisions

Section 4, Rule V of the New Rules of Procedure of the National Labor Relations Commission provides:

The Labor Arbiter shall take full control of the proceedings and shall limit the presentation of evidence to that which is relevant to the issues raised.

This provision grants the arbiter wide latitude to determine, after the submission of position papers and memoranda, whether there is need for a formal trial or hearing, which disposes of the first issue.

Ruling

On the first issue, the Court held that the Commission did not gravely abuse its discretion. ITELCO had repeatedly sought postponements and failed to appear, and the arbiter had expressly warned that no further motions would be entertained. A lawyer should not assume that a motion for postponement will be granted even if it bears the conformity of the other party, because the court is not bound thereby. Moreover, the holding of a trial is discretionary on the labor arbiter and cannot be demanded as a matter of right. The Court stressed the need for speedy disposition of labor cases, since parties may otherwise withhold evidence and create surprises that prolong the trial, and the need to lessen technicalities in settling labor disputes.

On the second issue, the Court held that the increase was proper. It distinguished the quantum of proof: criminal cases require proof beyond reasonable doubt, while labor proceedings require merely substantial evidence, which the Court described as such amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion. Thus, Attorney Ortega's acquittal is not incompatible with the finding that Praxides could not be totally blamed for desisting from work. The filing of the criminal complaint, the immediate report to the police, the medical treatment, and the affidavit were substantial evidence of the assault. Because the criminal complaint strained relations between the parties, separation pay in lieu of reinstatement was proper, and where reinstatement is no longer an option, separation pay equivalent to one month's salary for every year of service is awarded as an alternative.

Doctrine

First, the holding of a formal trial is discretionary on the labor arbiter and cannot be demanded as a matter of right; after position papers and memoranda are submitted, the arbiter may deem the case submitted for decision, and this does not amount to grave abuse of discretion. Second, labor proceedings require only substantial evidence, not proof beyond reasonable doubt, so an acquittal in a criminal case does not bar a labor finding of assault. Third, where reinstatement is no longer feasible because relations are strained, separation pay equivalent to one month's salary for every year of service is awarded in lieu of reinstatement.

Disposition

The petition was dismissed for lack of merit, with costs against ITELCO, and the Commission's resolution ordering separation pay of one month for every year of service was upheld.

Remember This

Memorize this line: a formal hearing in labor cases is discretionary, and substantial evidence suffices. Examiners use this case to test the distinction between substantial evidence and proof beyond reasonable doubt, and the rule on separation pay in lieu of reinstatement.