CASE DIGEST: BANTOLINO, ET AL. vs. COCA-COLA BOTTLERS PHILS., INC. G.R. No. 153660. June 10, 2003

Technical Rules Not Binding

FACTS:

62 Employees of Coca-Cola filed a complaint for unfair labor practice on grounds of illegal dismissal, violation of their security of tenure and the perpetuation of the "Cabo System". Due to employees' failure to prosecute, only 10 complainant continued and averred their complaints in a position paper. Coca-Cola filed a motion to dismiss contending that there is no employer-employee relationship between the company and the petitioners. The Labor Arbiter favors the petitioners and find that there is indeed an employer-employee relationship. On appeal, The NLRC sustained the finding of Labor Arbiter. Coca-Cola appealed to CA which although affirming the finding of the NLRC, nevertheless agreed with respondent that the affidavits of some of the complainants should not have given probative value for their failure to affirm the contents of and to undergo cross examination. As a consequence, the appellate court dismissed their complaints for lack of sufficient evidence.

ISSUE:

Whether CA is correct in dismissing the case of some petitioners by strictly applying the rules of procedure.

RULING:

No, administrative bodies like the NLRC are not bound by the technicalities 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. Under the rules of the Commission, The Labor Arbiter is given the discretion to determine the necessity of a formal trial or hearing. Hence, trial type hearings are not even required as the cases may be decided based on verified position papers, with supporting documents and their affidavits.