Case Digest (G.R. No. 143196)
Facts:
STI Drivers Association, Salvador Caranza, et al. v. Court of Appeals, Siment Transport, Inc., et al., G.R. No. 143196, November 26, 2002, Supreme Court Third Division, Corona, J., writing for the Court. The petitioners are a group of truck drivers and helpers who organized as the STI Drivers Association and registered with the Department of Labor and Employment; the respondents are Siment Transport, Inc. (STI), related business entities and owners (Ely Chua, William Chua, Simon Chuahe, Elizabeth Tan), and JRB Manpower Agency/Edwin Bumatay, and the Court of Appeals (as respondent insofar as its decision is assailed).Chronology: the drivers’ union filed a petition for certification election on May 2, 1994. On June 13, 1994, the med-arbiter dismissed that petition; the DOLE Undersecretary affirmed the dismissal on August 25, 1994. While that administrative appeal was pending, STI dismissed several drivers on June 29, 1994 allegedly for violating a union-security clause in the existing CBA with the Federation of Democratic Trade Unions—STI Workers Union (FDTU‑STI). The dismissed drivers filed complaints for illegal dismissal, unfair labor practice and damages before the Regional Arbitration Branch of the NLRC, and separately filed claims for underpayment of certain benefits.
Additional dismissals occurred: several truck helpers were dismissed for abandonment on July 13, 1994 after failing to report for work, and another group of drivers were dismissed on October 1, 1994 for failing to join the FDTU‑STI as required by the CBA. The cases were consolidated and initially raffled to Labor Arbiter Ernesto Dinopol, later re‑raffled to Labor Arbiter Romulus Protasio. The arbiter set reglementary periods for submission of position papers; petitioners did not file a position paper, and the arbiter proceeded ex parte, issuing a decision on April 21, 1995 dismissing the consolidated complaints.
The petitioners appealed to the NLRC on May 9, 1995, but the NLRC dismissed the appeal as filed out of time (June 30, 1995) and denied reconsideration. The petitioners then sought certiorari relief from the Court of Appeals; in CA‑G.R. SP No. 51216 the Court of Appeals (Sixth Division) affirmed the NLRC decision on July 26, 1999, holding that petitioners were not denied due process because their counsel of record had been notified and because their dismissal was justifiable under the contract‑bar rule (Articles 253 and 253‑A of the Labor Code). The petitioners then brought a petition for revie...(Pro-only)
Issues:
- Were the petitioners denied due process because they were represented by an impostor lawyer or non‑lawyer?...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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