Labor Jurisprudence

As we held in Huntington Steel Products, Inc. v.
National Labor Relations Commission, while

the requirement of strict compliance underscores the mandatory nature of the rule, it does not
necessarily interdict substantial compliance with its provisions under justifiable circumstances.
The rule should not be interpreted with such absolute literalness as to subvert its own ultimate
and legitimate objective which is the goal of all rules of procedure, that is, to achieve justice as
expeditiously as possible. A liberal application of the rule may be justified where special
circumstances or compelling reasons are present
[A]dministrative bodies are not bound by the technical niceties of law and procedure and the
rules obtaining in courts of law. Administrative tribunals exercising quasi-judicial powers are
unfettered by the rigidity of certain procedural requirements, subject to the observance of
fundamental and essential requirements of due process in justiciable cases presented before
them. In administrative proceedings, technical rules of procedure and evidence are not strictly
applied and administrative due process cannot be fully equated with due process in its strict
judicial sense
Samalio v. Court of Appeals, 494 Phil. 456, 464 (2005)
Barnes v. Hon. Quijano Padilla,95citing Sanchez v. Court of Appeals:96
In the Sanchez case, the Court restated the range of reasons whichmay provide justification for a
court to resist a strict adherence to procedure, enumerating the elements for an appeal to be given
due course by a suspension of procedural rules, such as: (a) matters of life, liberty, honor or
property; (b) the existence of special or compelling circumstances, (c) the merits of the case, (d) a
cause not entirely attributable to the fault or negligence of the party favored by the suspension of the
rules, (e) a lack of any showing that the review sought is merely frivolous and dilatory, and (t) the
other party will not be unjustly prejudiced thereby.97
In Republic v. Dagondon,98 the Court of Appeals dismissed petitioner's appeal for failure to timely file
a motion for reconsideration of the trial court decision.99 The Court of Appeals held that the trial court
decision "could no longer be assailed pursuant to the doctrine of finality and immutability of
judgments."100 This Court relaxed its application of the doctrine on immutability of judgment and held:
The mandatory character, however, of the rule on immutability of final judgments was not designed
to be an inflexible tool to excuse and overlook prejudicial circumstances. Hence, the doctrine must
yield to practicality, logic, fairness, and substantial justice.
G.R. No. 211526 June 29, 2016
PMI-FACULTY AND EMPLOYEES UNION, Petitioner,

vs.
PMI COLLEGES BOHOL, Respondent.
Moreover, it must be emphasized that the right to appeal should not be lightly disregarded by a
stringent application of rules of procedure especially where the appeal is on its face meritorious and
the interest of substantial justice would be served by permitting the appeal.27 This principle finds
particular significance in administrative and quasi-judicial bodies, like the NLRC, which are not
bound by technical rules of procedure in the adjudication of cases.
Had the CA also looked into the merits of the case, it could have found that the
Union’s certiorari petition was not without basis, as we shall discuss below. The case calls for a
resolution on the merits. And, although the Court is not a trier of facts, we deem it proper not to
remand the case to the CA anymore and to resolve the appeal ourselves, without further delay.
In Metro Eye Security, Inc., v. Julie V. Salsona,29 the Court avoided a remand of the case to the CA,
" x x x since all the records of this case are before us, there is no need to remand the case to the
Court of Appeals. On many occasions, the Court, in the public interest and for expeditious
administration of justice, has resolved actions on the merits, instead of remanding them for further
proceedings, as where the ends of justice would not be sub-served by the remand of the case."30 The
present case is in this same situation.
The CA decided the present labor dispute purely on technical grounds. Also, the respondent itself
would want the petition dismissed for alleged procedural lapses on the part of the Union.
After a careful study of the records, we find that the relaxation of the rules of procedure in this case
was the more prudent move to follow in the interest of substantial justice. Rules of procedure are not
inflexible tools designed to hinder or delay, but rather to facilitate and promote the administration of
justice. Their strict and rigid application which would result in technicalities that tend to frustrate
rather than promote substantial justice must always be eschewed.25 (Jaworski v. PAGCOR, 464 Phil.
375, 385 (2004).
Procedural rules were conceived to aid in the attainment of justice. If the stringent application of the
rules would hinder rather than service the demands of justice, the former must yield to the latter.26
(City of Dumaguete v. Philippine Ports Authority, 671 Phil. 610, 627 (2011), citing Basco v. CA, 392
Phil. 251, 266 (2000).)
G.R. No. 151349 October 20, 2010
LEANDRO M. ALCANTARA, Petitioner,

vs.
THE PHILIPPINE COMMERCIAL AND INTERNATIONAL BANK, Respondent.
There is ample jurisprudence holding that the subsequent and substantial compliance of an
appellant may call for the relaxation of the rules of procedure. In these cases,17 we ruled that the
subsequent submission of the missing documents with the motion for reconsideration amounts to
substantial compliance. The reasons behind the failure of the petitioners in these two cases to
comply with the required attachments were no longer scrutinized. What we found noteworthy in each
case was the fact that the petitioners therein substantially complied with the formal requirements.
We ordered the remand of the petitions in these cases to the Court of Appeals, stressing the ruling
that by precipitately dismissing the petitions "the appellate court clearly put a premium on
technicalities at the expense of a just resolution of the case."18
While it is true that the rules of procedure are intended to promote rather than frustrate the ends of
justice, and the swift unclogging of court docket is a laudable objective, it nevertheless must not be
met at the expense of substantial justice. This Court has time and again reiterated the doctrine that
the rules of procedure are mere tools aimed at facilitating the attainment of justice, rather than its
frustration. A strict and rigid application of the rules must always be eschewed when it would subvert
the primary objective of the rules, that is, to enhance fair trials and expedite justice. Technicalities
should never be used to defeat the substantive rights of the other party. Every party-litigant must be
afforded the amplest opportunity for the proper and just determination of his cause, free from the
constraints of technicalities. Considering that there was substantial compliance, a liberal
interpretation of procedural rules in this labor case is more in keeping with the constitutional
mandate to secure social justice.19 (Enriquez v. Bank of the Philippine Islands, G.R. No. 172812,
February 12, 2008)
Clearly, the Court of Appeals erred in dismissing petitioner’s special civil action for certiorari despite
subsequent substantial compliance with the rules on procedure, and in so doing, unduly upheld
technicalities at the expense of a just resolution of the case. Ordinarily, court procedure dictates that
the Court of Appeals should be tasked with properly disposing the petition, a second time around, on
the merits.
However, when there is enough basis on which a proper evaluation of the merits of petitioner’s case
may be had, the Court may dispense with the time-consuming procedure of remand in order to
prevent further delays in the disposition of the case.20 Clearly, a remand of the instant case to the
Court of Appeals would only unnecessarily prolong its resolution which had been pending for nearly
a decade.
It is already an accepted rule of procedure for us to strive to settle the entire controversy in a single
proceeding, leaving no root or branch to bear the seeds of future litigation. If, based on the records,
the pleadings, and other evidence, the dispute can be resolved by us, we will do so to serve the
ends of justice instead of remanding the case to the lower court for further proceedings.21 (Apo Fruits
Corporation v. Court of Appeals, G.R. No. 164195, February 6, 2007)
In any event, petitioner himself prayed that the Court resolve this case on the merits.22
The disposition of the technical issues paves the way for us to resolve the remaining substantive
issue concerning the validity of petitioner’s dismissal from employment.

Labor Jurisprudence

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As we held in Huntington Steel Products, Inc. v.

National Labor Relations Commission, while

Samalio v. Court of Appeals, 494 Phil. 456, 464 (2005)

Barnes v. Hon. Quijano Padilla,95citing Sanchez v. Court of Appeals:96

PMI-FACULTY AND EMPLOYEES UNION, Petitioner,

G.R. No. 151349 October 20, 2010

LEANDRO M. ALCANTARA, Petitioner,

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