G.R. No. 217575 - South Cotabato Communications Corp. vs. Sto. Tomas

On January 19, 2004, the Department of Labor and Employment Region-XII (DOLE) conducted a complaint inspection at DXCP Radio Station, owned by petitioner South Cotabato Communications Corporation.
Violations found included underpayment of wages, 13th month pay, non-payment of service incentive leave pay, rest day and holiday premium pay, and non-remittance of SSS contributions.
Some employees were paid on a commission basis aside from allowances.
DOLE issued a Notice directing petitioners to remedy violations within five days, but petitioners failed to comply.

DOLE scheduled summary investigations on March 3 and April 1, 2004; petitioners failed to appear for both hearings—first without explanation, second with a request to reset denied.
DOLE Hearing Officer consequently denied petitioners the chance to present evidence.

On May 20, 2004, DOLE Regional Director issued an Order directing petitioners to pay a total of ₱759,752 to private respondents for claims related to labor standards violations.
Petitioners appealed to the Secretary of Labor, arguing:

Denial of due process due to refusal to reset hearing; and
Lack of factual and legal basis, especially failing to establish an employer-employee relationship, which is necessary for DOLE’s jurisdiction.

Secretary of Labor affirmed DOLE Regional Director’s findings and monetary awards on November 8, 2004.

Petitioners sought reconsideration, which was denied.
Petitioners filed a petition for certiorari with the Court of Appeals (CA); initially dismissed on procedural grounds but later remanded by the Supreme Court for merits.
CA upheld the Secretary of Labor’s decision on November 28, 2014, with denial of petitioners’ motion for reconsideration on March 5, 2015.
Petitioner then elevated the case to the Supreme Court via a Petition for Review on Certiorari.

Private respondents filed a related illegal dismissal case with the National Labor Relations Commission (NLRC).
NLRC ruled in favor of petitioners stating no employer-employee relationship existed between parties, negating claims of constructive dismissal.
Petitioners argued that the CA and DOLE orders failed to address the employer-employee relationship, which is a jurisdictional requirement for DOLE to issue orders under Article 128 of the Labor Code.

Whether petitioners were denied due process when they were not allowed to present evidence at the DOLE summary investigation hearing.
Whether the DOLE and CA correctly found the existence of an employer-employee relationship between the petitioners and private respondents, thereby justifying DOLE’s exercise of jurisdiction and the issuance of monetary awards.
Whether the Orders of the DOLE Regional Director and Secretary of Labor are supported by substantial evidence and contain clear, factual, and legal bases as required under the Constitution.