Technical rules of procedure

Summary

▪ Technical rules of procedure are not binding in labor cases.

1. Concept

The rules of procedure and evidence prevailing in courts of law and equity shall not be controlling and the Commission shall use every and all reasonable means to ascertain the facts in each case speedily and objectively,  without regard to technicalities of law or procedure, all in the interest of due process. (Section 10, Rule VII, 2011 NLRC Rules of Procedure)

In labor cases, rules of procedure should not be applied in a very rigid and technical sense. They are merely tools designed to facilitate the attainment of justice, and where their strict application would result in the frustration rather than promotion of substantial justice, technicalities must be avoided. Technicalities should not be permitted to stand in the way of equitably and completely resolving the rights and obligations of the parties. Where the ends of substantial justice shall be better served, the application of technical rules of procedure may be relaxed. (Millennium Erectors Corporation v. Magallanes, G.R. No. 184362, 15 November 2010)

Administrative bodies like the NLRC are not bound by the technical niceties of law and procedure and the rules obtaining in courts of law. Indeed, the Revised Rules of Court and prevailing jurisprudence may be given only stringent application, i.e., by analogy or in a suppletory character and effect. The submission by [a party], citing People v. Sorrel, that an affidavit not testified to in a trial, is mere hearsay evidence and has no real evidentiary value, cannot find relevance in the present case considering that a criminal prosecution requires a quantum of evidence different from that of an administrative proceeding. (JR Hauling Services v. Solamo, G.R. No. 214294, 30 September 2020)

2. Purpose

a. Administration of justice

Indeed, technical rules of procedure are not binding in labor cases. The LAs and the NLRC are mandated to use every and all reasonable means to ascertain the facts in each case speedily and objectively, without regard to technicalities of the law or procedure. Nevertheless, though technical rules of procedure are not ends in themselves, they are necessary for an effective and expeditious administration of justice. (Azuelo v. ZAMECO II Electric Cooperative, Inc., G.R. No. 192573, 22 October 2014)

b. Not a license to disregard

The non-applicability of technical rules of procedure in labor cases should not be made a license to disregard the rights of employers against unreasonable and/or unjustified claims. [The employee} was given sufficient chances to establish his claim against [the employer], which he failed to do when he did not submit his position paper despite several extensions granted him. He cannot now be allowed to raise anew his supposed illegal dismissal as it would be plainly unjust to [the employer]. It bears stressing that the expeditious disposition of labor cases is mandated not only for the benefit of the employees, but of the employers as well. (Ibid.)

2. Evidence on Appeal

a. NLRC

Verily, labor tribunals, such as the NLRC, are not precluded from receiving evidence submitted on appeal as technical rules are not binding in cases submitted before them. In fact, labor officials should use every and reasonable means to ascertain the facts in each case speedily and objectively, without regard to technicalities of law or procedure, all in the interest of due process. (Surigao del Norte Electric Cooperative, Inc. v. Gonzaga, G.R. No. 187722, 10 June 2013)

The Court had declared in previous cases that strict adherence to the technical rules of procedure is not required in labor cases. However, the Court also highlights that in such cases, it had allowed the submission of evidence for the first time on appeal with the NLRC in the interest of substantial justice, and had further required for the liberal application of procedural rules that the party should adequately explain the delay in the submission of evidence and should sufficiently prove the allegations sought to be proven. (Princess Talent Center Production, Inc. v. Masagca, G.R. No. 191310, 11 April 2018)

3. Delayed submission of evidence

a. Justification and evidence is material

In labor cases, strict adherence with the technical rules is not required. This literal policy, however, should still conform with the rudiments of equitable principles of law. For instance, belated submission of evidence may only be allowed if the delay is adequately justified and the evidence is clearly material to establish the party’s cause. (Misamis Oriental II Electric Service Cooperative [MORESCO II] v. Cagawalan, G.R. No. 175170)

Where an employer did not submit the evidence during the administrative proceedings before the Labor Arbiter and NLRC or even during the certiorari proceedings before the Court of Appeals, and it did not offer any explanation at all as to why they are submitting the evidence only on appeal before this Court. Hence, the Court is not inclined to relax the rules in the present case in the employer’s favor. (Princess Talent Center Production, Inc. v. Masagca, supra.)

4. Right to appeal

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. 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. (PMI-Faculty and Employees Union v. PMI Colleges Bohol, G.R. No. 211526, 29 June 2016)

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References

▪ 2011 NLRC Rules of Procedure, as amended

▪ Jurisprudence or Supreme Court Decisions (as cited above)