G.R. No. 101527 - Imperial Textile Mills, Inc. vs. National Labor Relations Commission

Angie Mendoza (private respondent) had been employed with Imperial Textile Mills, Inc. (petitioner) since 1977.
She rose through petitioner’s ranks from secretary to the Finishing Department Head, to secretary to the Executive Vice President, and later to personnel manager up to March 7, 1986.
Her latest salary was P6,190.00.

Mendoza wrote the widow of the former president of petitioner.
In her letter, Mendoza stated that, upon the expiration of an approved one-month vacation leave on March 7, she reported as promised but found that major changes had taken place during her absence.
She stated that the position of personnel manager had been filled by a newcomer.
She requested that she cease employment “in view of the above circumstances,” with “equivalent separation pay.”
She described herself as a pioneer employee and recounted her career progression.
She ended by requesting consideration and immediate attention to her request.

On June 6, 1986, Mendoza filed the “instant complaint for illegal dismissal.”
Mendoza alleged that she was dismissed without sufficient grounds after 14 years of service.

Petitioner averred that Mendoza voluntarily resigned.
Petitioner claimed that if Mendoza was terminated, the termination was due to valid and just grounds.
Petitioner further asserted that, as a managerial employee, Mendoza could be terminated for loss of trust and confidence.

Mendoza’s position paper was unverified and should be stricken off the record.
Mendoza failed to appear despite notice, depriving petitioner of the opportunity to cross-examine her.

In an order dated May 25, 1988, the labor arbiter dismissed the complaint without prejudice.
The labor arbiter grounded the dismissal on the premise that Mendoza’s absence deprived petitioner of the opportunity to cross-examine her.

On appeal, the National Labor Relations Commission (NLRC) reversed the labor arbiter in a decision dated October 28, 1988.
The NLRC held that under Article 221 of the Labor Code, the NLRC and the labor arbiter had authority to decide cases based on position papers and documents submitted by the parties without resorting to technical rules of evidence.
The NLRC held that petitioner was not denied due process because, based on the records, an intelligent decision could be arrived at without a formal hearing.
Petitioner then filed a certiorari petition to this Court, docketed as G.R. No. 86663, entitled “Imperial Textile Mills, Inc. vs. National Labor Relations, et. al.”
In a resolution dated February 15, 1989, this Court dismissed G.R. No. 86663.

After remand, the labor arbiter rendered a decision dated April 10, 1990.
The labor arbiter declared that Mendoza’s dismissal was legally effected on the ground that she resigned voluntarily.
The labor arbiter also found that her dismissal was for a valid cause, specifically loss...(Subscriber-Only)

Whether petitioner was denied due process due to lack of opportunity to cross-examine Mendoza during the labor arbiter hearing.
Whether the NLRC could decide based on position papers when Mendoza’s position paper was allegedly unverified.
Whether the NLRC erred in finding that petitioner failed to prove loss of trust and confidence and in concluding that Mendoza was illegally dismissed.
Whether the labor arbiter’s findings of fact should have been respected and treated as final due to an alleged late appeal by...(Subscriber-Only)