November 25, 2022 @ 1:20 AM 2 months ago

THE technical niceties of the rules obtaining in a court of law are not strictly applied in proceedings before the National Labor Relations Commission.

Stated otherwise, strict adherence to the technical rules of procedure is not required in labor cases.

Why are the technical rules of procedure not applicable in labor cases?

In a plethora of cases, the Supreme Court has consistently held that procedural rules should not be applied in a very rigid and strict sense. This is especially true in labor cases wherein the substantial merits of the case must accordingly be decided upon to serve the interest of justice. (Millenium Erectors Corporation vs. Magallanes, November 15, 2010; Anib vs. Cola-Cola Bottlers Phils., Inc., August 16, 2010)


Rules of technicality must yield to the broader interest of justice. And procedural rules should be relaxed-if only to serve the ends of justice.

Thus, proceedings before the NLRC need not adhere strictly to technicalities as long as substantive justice is attained; technical rules of procedure may be relaxed in the interest of substantial justice and to assist the parties in obtaining just, expeditious and inexpensive resolution and settlement of labor disputes. (Beltran vs. AMA Computer College-Binan/AMA Education System, April 3, 2019)

In fact, labor officials are enjoined to use every and reasonable means to ascertain the facts in each case speedily and objectively, without regard to technicalities of law or procedure, in the interest of due process. (Quantum Foods, Inc. vs. Marcelino Esloyo, December 9, 2015)

To illustrate (since technical rules are not binding in cases filed before the NLRC), evidence may be submitted for the first time on appeal with the NLRC in the interest of substantial justice.

The High Court, in the case of Mariano vs. G.V. Florida Transport (September 16, 2020), clarified that “[L]abor 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. There is, however, a caveat to this policy. The delay in the submission of evidence should be adequately explained, the evidence adduced must be undeniably material to the cause of a party, and the subject evidence should sufficiently prove the allegations sought to be established.”


It is well to emphasize that the quantum of proof necessary to establish one’s claims in labor (and administrative) cases is substantial evidence-or such amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion even if other equally reasonable minds might conceivably opine otherwise.

And the burden of proof rests upon the party who asserts the affirmative of an issue. (Beltran vs. AMA Computer College-Binan/AMA Education System, April 3, 2019).