G.R. No. L-37034 - Jacqueline Industries vs. National Labor Relations Commission

Petitioners: Jacqueline Industries, Dunhill Bags Industries, Pol Yap, Candido Dyonco, and Henry Yap.
Respondents: National Labor Relations Commission (NLRC) and private respondent Gaudencia de Quiroz.
The case involves a money claim arising from labor-related issues, with the dispute centering on payments and benefits under various labor laws.

An adverse decision was promulgated on August 29, 1975, dismissing the suit for certiorari and prohibition while sustaining Gaudencia de Quiroz’s claim.
Petitioners, contesting this decision, filed a motion for reconsideration or a new trial on October 13, 1975, subsequently formalized on December 15, 1975.

Petitioners asserted that there was a denial of due process owing to the absence of a proper hearing.
They argued they were not given the adequate opportunity to present evidence or be heard regarding the dispute.

Petitioners contended that the employer-employee relationship had ceased since the private respondent had been dismissed and did not seek reinstatement or appeal against the dismissal.

Petitioners sought to introduce the defense that the claim was barred by prescription or laches, arguing that enough time had elapsed to undermine Gaudencia de Quiroz’s claim.

Atty. Luna C. Piezas conducted preliminary fact-finding hearings on January 31, 1973, and February 6, 1973.
A Fact-Finding Report was duly submitted on February 7, 1973 in compliance with the NLRC rules as implemented under Presidential Decree No. 21.

Hearings were conducted at the mediation level on February 16 and February 22, 1973 by the designated Mediator/Fact-Finder.
Subsequent mediation reports were submitted, which formed the basis for the NLRC’s decision.

Both petitioners and the private respondent presented documentary and testimonial evidence during these hearings.
Occasional ex parte hearings, if any, were attributed to the non-appearance or unexplained absence of petitioners or their counsel.

Respondents (via a three-page comment signed by Solicitor General Estelito P. Mendoza and colleagues) provided a comprehensive counter-comment addressing all points raised by petitioners.
The NLRC established that the hearings were conducted in accordance with their non-litigious and summary administrative procedures under Section 9 and Section 28 of Presidential Decree No. 21.
The established record of proceedings demonstrated that petitioners were given every opportunity to be heard despite their claims.

Whether the alleged denial of due process occurred because of the absence of a proper hearing at the mediation level.
Whether the employer-employee relationship between petitioners and the private respondent was effectively terminated by the dismissal, or if it continued notwithstanding the alleged unlawful dismissal.
Whether petitioners could validly raise the defense of prescription or laches for the first time on appeal or in a motion for reconsideration.
Whether the procedural and substantive bases of the NLRC’s decision were sound enough to justify denying petitioners’ motion for reconsideration or a new trial.