PETITIONER Allan John Uy Reyes filed a complaint for illegal dismissal against respondent Global Beer Below Zero, Inc.
Both the Labor Arbiter (LA) and the National Labor Relations Commission (NLRC) found for the petitioner.
Respondent filed with the Court of Appeals (CA) a petition for certiorari. The CA reversed the decision of the NLRC. It ruled that the text messages sent by Co Say and Tet Manares of respondent to petitioner could hardly meet the standard of clear, positive, and convincing evidence to prove petitioner’s dismissal from employment.
The text message from Say read:,“Tet will contact you plus turnover.” Did the CA err?
Ruling: Yes.
Interestingly, the text message of respondent Co Say was followed by another message from Ms. Tet Manares, which stated that, “Kuya, pinaayos ko na kay gen salary mo.” This is consistent with the first message that Tet will contact the complainant. True enough, Manares contacted the complainant informing him that his salary was already being prepared.
The two text messages, when taken together, support complainant’s insistence that he was actually dismissed from his work. Respondent Co Say’s text message regarding “turnover” and Manares’ text message regarding the preparation of the complainant’s salary were quite consistent with the complainant’s allegation that he was dismissed by respondent Co Say during their telephone conversation and during their meeting at Starbucks Waltermart.
The respondents’ assertion that the purported text messages submitted by the complainant should not be given credence as the complainant failed to authenticate the same in accordance with the Rules of Court, deserves scant consideration.
It must be emphasized that in labor cases, the strict adherence to the rules of evidence may be relaxed consistent with the higher interest of substantial justice.
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. (Tres Reyes v. Maxim’s Tea House, G.R. No. 140853, February 27, 2003, 398 SCRA 288).
It is well settled that the application of technical rules of procedure may be relaxed to serve the demands of substantial justice, particularly in labor cases. Thus, the “text” messages may be given credence, especially if they corroborate the other pieces of evidence presented.
Again, while as a rule, the Court strictly adheres to the rules of procedure, it may take exception to such general rule when a strict implementation of the rules would cause substantial injustice to the parties. (Peralta, J., SC 2nd Division, Allan John Uy Reyes vs. Global Beer Below Zero, Inc., G.R. No. 222816, October 04, 2017).