Facts:

• C.W. Tan Manufacturing and its officials, Federico Javier and Jaime So, are petitioners against the NLRC, Associated Labor Unions (ALU), and Angelino Brimon.
• On May 2, 1982, ALU and Brimon filed a complaint for illegal dismissal against the petitioners.
• Brimon was dismissed for undesirable behavior, including coercing coworkers and disrespecting superiors.
• His dismissal followed a denied leave request on March 2, 1982, and subsequent allegations of lying about it.
• Labor Arbiter Porfirio E. Villanueva ruled on October 21, 1982, that Brimon's dismissal was valid and due process was followed.
• Brimon's appeal to the NLRC was dismissed on May 28, 1984, due to lack of proof of service.
• After a motion for reconsideration, the NLRC reinstated Brimon on March 12, 1987, citing arbitrary dismissal without formal investigation.
• The petitioners' motion for reconsideration was denied on July 20, 1987, leading to the current petition questioning the finality of the labor arbiter's decision.

Issue:

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Ruling:

• The Supreme Court ruled that failing to furnish a copy of the appeal memorandum is not a jurisdictional defect but a formal lapse.
• Delayed payment of the appeal fee does not invalidate the appeal; it should proceed in the interest of justice.
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Ratio:

• The Court determined that the requirement to provide a copy of the appeal memorandum is procedural, and compliance, even if late, should be accepted to serve justice.
• Previous rulings support that procedural lapses should not obstruct justice, especially when case merits warrant revi...continue reading