In Bantolino v. Coca-Cola Bottlers Phils., Inc., the Supreme Court ruled that labor tribunals like the NLRC aren’t strictly bound by courtroom evidence rules. This means labor cases can be decided using position papers and affidavits, even if the people who made the affidavits aren’t cross-examined. The ruling underscores the flexible approach to evidence in labor disputes, prioritizing a speedy and objective resolution over strict adherence to courtroom formalities.

When Employment Claims Rely on Affidavits: A Bottler’s Dispute

The case originated from a complaint filed by sixty-two (62) employees of Coca-Cola Bottlers, Inc. and its officers. They alleged unfair labor practices, including illegal dismissal and violation of their security of tenure. The employees sought reinstatement with back wages and a declaration of their regular employment status. The central legal question was whether the National Labor Relations Commission (NLRC) correctly gave evidentiary weight to the affidavits of the complainants, despite the failure of some affiants to affirm their contents through cross-examination.

The Labor Arbiter initially ruled in favor of the employees, ordering their reinstatement with back wages. The arbiter found their testimonies more credible than the employer’s denials, as they provided detailed accounts of their employment. On appeal, the NLRC affirmed the Labor Arbiter’s decision, sustaining the finding of an employer-employee relationship. However, the Court of Appeals partially reversed this decision. The appellate court held that the affidavits of some employees lacked probative value because they were not affirmed through cross-examination.

The Supreme Court, however, sided with the employees, reversing the Court of Appeals’ decision. The Court emphasized that administrative bodies like the NLRC are not strictly bound by the technical rules of evidence applicable in regular courts. It cited Article 221 of the Labor Code, which authorizes labor arbiters and the NLRC to adopt reasonable means to ascertain facts speedily and objectively, without regard to technicalities. The court explained that requiring strict adherence to courtroom evidence rules in labor cases would negate the purpose of summary proceedings.

Under Art. 221 of the Labor Code, the rules of evidence prevailing in courts of law do not control proceedings before the Labor Arbiter and the NLRC. Further, it notes that the Labor Arbiter and the NLRC are authorized to adopt reasonable means to ascertain the facts in each case speedily and objectively and without regard to technicalities of law and procedure, all in the interest of due process.

The Supreme Court cited its earlier rulings in Rabago v. NLRC and Rase v. NLRC, which upheld the use of affidavits in labor cases even without cross-examination. It clarified that while the Revised Rules of Court and jurisprudence could be applied, their application is limited to analogy or suppletory character. This means the Labor Arbiter has discretion to determine whether a formal trial or hearing is necessary. Decisions can be based on verified position papers, supporting documents, and affidavits.

Addressing the issue of Nestor Romero’s inclusion in the case, the Court referred to Periquet v. NLRC, which provides guidelines for valid compromise agreements, waivers, and quitclaims. The Court found that Romero’s Compromise Agreement and Release, Waiver and Quitclaim were valid because they did not indicate any inequity. The Court also noted there was no attempt by the parties to disavow the agreement’s execution. Therefore, the Supreme Court determined Romero should not be included in the petition’s benefits.

The Supreme Court also addressed the technicality that not all petitioners signed the petition or the Verification and Certification of Non-Forum Shopping. It noted that at the time the petition was filed, the petitioners were not yet represented by counsel. Therefore, the Court found that they could not be faulted for this procedural lapse because as non-lawyers, they could not be expected to be familiar with the nuances of law or the technicalities of procedure.

FAQs

What was the key issue in this case?	The key issue was whether the affidavits presented by the employees should be given evidentiary weight, even though some affiants did not undergo cross-examination.
Did the Court of Appeals and NLRC agree on the decision?	No, the NLRC initially ruled in favor of the employees, while the Court of Appeals partially reversed the decision, questioning the affidavits’ validity without cross-examination.
What does the Labor Code say about evidence rules in labor cases?	Article 221 of the Labor Code states that the rules of evidence in courts of law do not strictly apply to proceedings before Labor Arbiters and the NLRC, allowing flexibility.
Why did the Supreme Court reverse the Court of Appeals’ decision?	The Supreme Court reversed the Court of Appeals because administrative bodies like the NLRC are not bound by strict courtroom rules of evidence and can rely on affidavits.
What is the significance of the Periquet v. NLRC case in this context?	Periquet v. NLRC outlines the parameters for valid compromise agreements and quitclaims, which the Court used to determine the validity of Nestor Romero’s settlement.
What was the outcome for Nestor Romero in this case?	Nestor Romero, who had entered into a compromise agreement with Coca-Cola Bottlers, was excluded from the benefits granted to the other employees in the final decision.
What did the court say about the absence of the petitioners signatures?	The Court explained that non-lawyer petitioners who are without counsel during the petition’s filing could be excused for some technical mistakes.
What are the practical implications of this ruling for employees and employers?	The case reinforces the principle that labor tribunals prioritize a speedy and objective resolution over strict adherence to courtroom formalities.

The Supreme Court’s decision in Bantolino v. Coca-Cola Bottlers clarifies the scope of evidentiary rules in labor disputes, affirming that administrative bodies like the NLRC have the flexibility to consider affidavits even without cross-examination, to ensure a speedy and just resolution of labor claims. This case also clarifies the extent of how administrative technicalities are regarded by the Court when one or more parties are unrepresented by a legal counsel.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Prudencio Bantolino, et al. vs. Coca-Cola Bottlers Phils., Inc., G.R. No. 153660, June 10, 2003