Case Digest (G.R. No. 134903)
Facts:
Unicraft Industries International Corporation, Robert Dino, Cristina Dino and Michael Lloyd Dino v. The Hon. Court of Appeals, et al., G.R. No. 134903, January 16, 2002, Supreme Court First Division, Ynares‑Santiago, J., writing for the Court.
The petitioners are Unicraft Industries International Corporation and certain officers of the company; the private respondents are a number of former employees who filed labor complaints. The proceedings began with complaints for illegal dismissal and related money claims filed with the National Labor Relations Commission Regional Arbitration Branch (NLRC RAB), Cebu City, in July 1995.
After preliminary proceedings and submission of position papers before the NLRC RAB, the case was referred to voluntary arbitration under NCMB Policy Instruction No. 56. Florante V. Calipay was designated voluntary arbitrator in December 1996. On January 23, 1997 the arbitrator ordered both parties to submit position papers and evidence within 15 days; he extended the deadline to February 17, 1997 and warned that failure to comply would be deemed a waiver. Private respondents filed their position paper and evidence by mail within the extended period; petitioners did not.
The arbitrator set a final hearing for March 3, 1997 at 3:00 P.M.; petitioners say they received notice only at 4:00 P.M. of that date and therefore failed to attend. The March 3 hearing proceeded in petitioners’ absence and, on March 15, 1997, the voluntary arbitrator rendered a Decision declaring private respondents illegally dismissed and awarding backwages, separation pay, money claims and attorneys’ fees.
Subsequently the parties executed a stipulation (approved by the Court of Appeals on April 22, 1997) agreeing to refer the case back to Voluntary Arbitrator Calipay so petitioners would be granted their day in court and on condition that petitioners post a P6.5 million bond. The stipulation fixed the issues to be reopened before the arbitrator. The proceedings were not continued, however, because the voluntary arbitrator had declared he had lost jurisdiction upon rendering his Decision.
Despite the stipulation, the Court of Appeals issued a resolution on June 18, 1998 ordering partial execution of the arbitrator’s decision as to separation pay and attorneys’ fees. Petitioners challenged these actions up to the Supreme Court. On March 26, 2001 the Court rendered a Decision annulling the assailed Court of Appeals resolutions and the voluntary arbitrator’s decision and remanding the case to the voluntary arbitrator for reception of evidence for petitioners.
Private respondents filed a Motion for Reconsideration (May 15, 2001), a Supplemental Motion (July 30, 2001), and a Second Supplemental Motion...(Pro-only)
Issues:
- Were petitioners deprived of due process in the voluntary arbitration proceedings such that the Supreme Court properly remanded the case to the voluntary arbitrator for reception of evidence?
- Could the award of separation pay (and partial execution of that award) be lawfully executed before the arbitration proceedings...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)