Facts:

The case at hand is St. Michael Security Service vs. Hon. Amado G. Inciong, Acting Secretary of Labor and others, decided by the Supreme Court of the Philippines on August 31, 1978. The petitioner, St. Michael Security Service, contested the decision rendered by Labor Arbiter Cresencio J. Ramos, which ordered the company to return a total of P3,840.00 to several private respondents — namely Maria Rodriguez, Casimiro O. Geroza, Rogelio Zaratan, Bernardino Beltran, and Crisanto Retutar. This amount represented illegal deductions made from their salaries without the requisite authorization.

The dispute began with the filing of a complaint by the private respondents due to non-payment and improper deductions from their wages while employed as security guards. Initially handled by Labor Arbiter Edna B. Perez, St. Michael Security Service neglected to attend several hearings, causing the Arbiter to receive testimonies ex parte. Eventually, the case was transferred to Labor Arbiter Ra

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Facts:

Parties and Nature of the Case

• Petitioner: St. Michael Security Service, challenging the decision.
• Respondents:
• Acting Secretary of Labor, Amado G. Inciong
• National Labor Relations Commission (NLRC) Commissioners: Diego P. Atienza, Geronimo G. Quadra, and Cleto T. Villanueva
• NLRC Labor Arbiters: Cresencio J. Ramos and Antonio Tria Tirona
• Deputy Sheriff: Leon Navea
• Private respondents (security guards): Maria Rodriguez, Casimiro O. Geroza, Rogelio Zaratan, Bernardino Beltran, and Crisanto Retutar
• Subject Matter: The dispute arose from claims of illegal salary deductions from former security guards employed by the petitioner. The labor arbiters had rendered an award directing the petitioner to refund a total of P3,840.00 pesos apportioned among the private respondents.

Chronology and Background of Proceedings

• Initial Proceedings
• The case was first handled by Labor Arbiter Edna B. Perez, during which the petitioner failed to appear at three hearings.
• Due to nonappearance, the complainants’ evidence was taken ex parte against the petitioner.
• Subsequent Handling by Labor Arbiter Ramos
• Upon taking over the case, Arbiter Ramos noted that earlier hearing notices had not been delivered because of the petitioner’s change of address.
• The petitioner’s manager, who continued to reside at the former address, ultimately received a notice for a rescheduled hearing.
• Again, the petitioner did not appear, prompting Arbiter Ramos to decide the case based solely on the complainants’ joint affidavit.
• Decisions and Appeals
• The Labor Arbiter’s decision, which relied on the joint affidavit of the complainants detailing salaries, periods of employment, and unauthorized deductions, was upheld.
• An appeal was made to the NLRC on grounds of alleged abuse of discretion; however, the appeal was dismissed as the evidence was deemed sufficient.
• The petitioner further raised the due process issue alleging both procedural and substantive violations, which also failed at subsequent stages, including before the Acting Secretary of Labor.
• Execution and Further Relief Sought
• Following the finality of the NLRC decision, a writ of execution was issued to enforce the refund order against the petitioner.
• The petitioner then elevated the matter by filing a petition for certiorari, contending that there was a denial of due process.

Intervention of Government Counsel and Comments

• The due process allegations were robustly refuted by government counsel, Solicitor General Estelito P. Mendoza.
• His comment clarified that:
• The petitioner was given proper and sufficient notice of all hearing dates.
• It was the petitioner’s default and refusal to appear that led to the adverse ruling, not any failure on the part of the respondents to observe the procedural due process requirements.

Issue:

Procedural Due Process

• Whether the petitioner’s due process rights were violated in terms of proper notice and opportunity to be heard.
• Whether the failure to personally receive the telegrams or attend hearings, despite being duly notified, constitutes a due process violation.

Substantive Due Process

• Whether the award entered by Labor Arbiter Ramos was arbitrary or capricious.
• Whether the evidence presented (i.e., the joint affidavit of the complainants) was sufficient to support the award despite the petitioner’s nonappearance.

Validity of the Award

• Whether the subsequent rulings by the NLRC Commissioners and the Acting Secretary of Labor, as well as the issuance of a writ of execution, were justified and free from due process defects.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)