DOCTRINE:
FACTS:
ISSUE:
- The Rules of Court, specifically on Rules of Evidence does not strictly apply to an administrative body performing quasi-judicial functions.
- The failure of the affiants to appear in court for purposes of cross-examination shall not render their affidavits inadmissible as it will negate the rationale and purpose of the nature of summary proceedings.
- Strict observance of the rules with respect to Verification and Certification of Non-Forum Shopping allows an exception upon showing of reasonable cause for failure to observe the same.
- A waiver and quitclaim which is contrary to public policy may be recognized as valid and binding if the agreement is voluntarily entered into and represents a reasonable settlement. Where a person making the waiver did so voluntarily, with full understanding of what he was doing, and the consideration of the quitclaim is credible and reasonable, the transaction shall be valid and binding.
FACTS:
- 62 employees of the Coca-Cola (the company) filed a complaint for unfair labor practice.
- Allegedly, the employees, in the performance of their duties as route helpers, bottle segregators, and others, where replaced and prevented from entering the company premises.
- Such act by the employer is deemed an illegal dismissal.
- The company averred that there was no employer-employee relationship thus the Labor Arbiter has no jurisdiction.
- The Labor Arbiter then rendered a decision in favor of the employees and ordering the company to reinstate the complainants to their former posistions with all the rights, privileges and benefits due regular employees, and to pay their full back wages.
- Coca-Cola then appealed the decision to the NLRC which sustained the findings of the Labor Arbiter.
- Then, the company elevated the matter to the Court of Appeals which affirmed the existence of an employer-employee relationship but set aside the favorable decision of 7 employees for lack of sufficient evidence.
- According to the CA, the affidavits of the 7 employees should not have been given probative value for their failure to affirm the contents thereof and to undergo cross-examination.
- Only those 3 employees where declared regular employees since they were the only ones subjected to cross-examination.
ISSUE:
WON the affidavits should be given probative value despite the failure of the affiants to affirm their contents and undergo test of cross-examination.
HELD:
The Rules of Evidence are not strictly observed in proceedings before administrative bodies like the NLRC where decisions may be reached on the basis of position papers only. Citing Rase v. NLRC, tt was not necessary for the affiants to appear and testify and be cross-examined as it would negate the rationale and purpose of the summary nature of the proceedings mandated by the Rules and to make mandatory the application of the technical rules of evidence.
