1) Petitioners appealed a Court of Appeals decision that dismissed the complaints of some employees against their employer for failure to affirm their affidavit contents and undergo cross-examination.
2) While the NLRC found an employer-employee relationship and ordered reinstatement, the Court of Appeals only affirmed this for employees who were cross-examined.
3) The Supreme Court ruled that the Court of Appeals erred in dismissing the complaints as administrative bodies like the NLRC are not bound by technical court rules of evidence and procedure, and can determine cases based on position papers and affidavits.
1) Petitioners appealed a Court of Appeals decision that dismissed the complaints of some employees against their employer for failure to affirm their affidavit contents and undergo cross-examination.
2) While the NLRC found an employer-employee relationship and ordered reinstatement, the Court of Appeals only affirmed this for employees who were cross-examined.
3) The Supreme Court ruled that the Court of Appeals erred in dismissing the complaints as administrative bodies like the NLRC are not bound by technical court rules of evidence and procedure, and can determine cases based on position papers and affidavits.
1) Petitioners appealed a Court of Appeals decision that dismissed the complaints of some employees against their employer for failure to affirm their affidavit contents and undergo cross-examination.
2) While the NLRC found an employer-employee relationship and ordered reinstatement, the Court of Appeals only affirmed this for employees who were cross-examined.
3) The Supreme Court ruled that the Court of Appeals erred in dismissing the complaints as administrative bodies like the NLRC are not bound by technical court rules of evidence and procedure, and can determine cases based on position papers and affidavits.
1) Petitioners appealed a Court of Appeals decision that dismissed the complaints of some employees against their employer for failure to affirm their affidavit contents and undergo cross-examination.
2) While the NLRC found an employer-employee relationship and ordered reinstatement, the Court of Appeals only affirmed this for employees who were cross-examined.
3) The Supreme Court ruled that the Court of Appeals erred in dismissing the complaints as administrative bodies like the NLRC are not bound by technical court rules of evidence and procedure, and can determine cases based on position papers and affidavits.
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BANTOLINO v. COCA-COLA BOTTLERS PHILS., INC.
declared regular employees since they were the only ones subjected to cross- G.R. No. 153660 June 10, 2003 examination. Petitioners now pray for relief from the adverse Decision of the Court of Appeals; that, instead, the favorable judgment of the NLRC be reinstated. BELLOSILLO, J.: Issue: Procedural History: Whether or not the Court of Appeals erred in dismissing their complaints This is a Petition for Review on Certiorari assailing the Decision of the for failure to affirm the contents thereof and to undergo cross-examination Court of Appeals dated December 21, 2001 which affirmed with modification the decision of the National Labor Relations Commission promulgated 30 March 2001 Answer: wherein petitioners were denied to be reinstated because of failure to affirm the Yes. Administrative bodies like the NLRC are not bound by the technical contents of their affidavits and to undergo cross-examination. niceties of law and procedure and the rules obtaining in courts of law.
Statement of facts: Holding:
On February 25, 1995 sixty-two (62) employees of respondent Coca-Cola Southern Cotabato Dev. and Construction Co. v. NLRC11 succinctly states Bottlers, Inc., and its officers, Lipercon Services, Inc., People's Specialist Services, that under Art. 221 of the Labor Code, the rules of evidence prevailing in courts of Inc., and Interim Services, Inc., filed a complaint against respondents for unfair labor law do not control proceedings before the Labor Arbiter and the NLRC. Further, it practice through illegal dismissal, violation of their security of tenure and the notes that the Labor Arbiter and the NLRC are authorized to adopt reasonable means perpetuation of the "Cabo System." They thus prayed for reinstatement with full back to ascertain the facts in each case speedily and objectively and without regard to wages, and the declaration of their regular employment status. technicalities of law and procedure, all in the interest of due process. We find no compelling reason to deviate therefrom. For failure to prosecute as they failed to either attend the scheduled mandatory conferences or submit their respective affidavits, the claims of fifty-two The Revised Rules of Court and prevailing jurisprudence may be given only (52) complainant-employees were dismissed. Thereafter, Labor Arbiter Jose De Vera stringent application, i.e., by analogy or in a suppletory character and effect. The conducted clarificatory hearings to elicit information from the ten (10) remaining submission by respondent, citing People v. Sorrel,12 that an affidavit not testified to complainants (petitioners herein) relative to their alleged employment with in a trial, is mere hearsay evidence and has no real evidentiary value, cannot find respondent firm. relevance in the present case considering that a criminal prosecution requires a quantum of evidence different from that of an administrative proceeding. Under the On May 29, 1998 Labor Arbiter Jose De Vera rendered a decision ordering Rules of the Commission, the Labor Arbiter is given the discretion to determine the respondent company to reinstate complainants to their former positions with all the necessity of a formal trial or hearing. Hence, trial-type hearings are not even required rights, privileges and benefits due regular employees, and to pay their full back wages as the cases may be decided based on verified position papers, with supporting which, with the exception of Prudencio Bantolino whose back wages must be documents and their affidavits. We cannot likewise accommodate respondent's computed upon proof of his dismissal as of 31 May 1998. On appeal, the NLRC contention that the failure of all the petitioners to sign the petition as well as the sustained the finding of the Labor Arbiter that there was indeed an employer- Verification and Certification of Non-Forum Shopping in contravention of Sec. 5, employee relationship between the complainants and respondent company when it Rule 7, of the Rules of Court will cause the dismissal of the present appeal. affirmed in toto the latter's decision.
Respondent Coca-Cola Bottlers appealed to the Court of Appeals which,
although affirming the finding of the NLRC that an employer-employee relationship existed between the contending parties, nonetheless agreed with respondent that the affidavits of some of the complainants, namely, Prudencio Bantolino, Nestor Romero, Nilo Espina, Ricardo Bartolome, Eluver Garcia, Eduardo Garcia and Nelson Manalastas, should not have been given probative value for their failure to affirm the contents thereof and to undergo cross-examination. As a consequence, the appellate court dismissed their complaints for lack of sufficient evidence. In the same Decision however, complainants Eddie Ladica, Arman Queling and Rolando Nieto were
