NATIONAL Labor Relations Commission (NLRC) Sheriff Manolito G. Manuel subjected to levy and execution certain machinery equipment, tools and implements owned by UE Automotive Manufacturing, Inc. (UEAMI). The levy was made pursuant to a final and executory NLRC judgment against UEAMI in an illegal dismissal case, in which it was ordered to pay P53,729,534 to complainants UEAMI Monthly Associates and UE Automotive Workers Union-NFL.
Metrobank filed an Affidavit of Third-Party claim with the Labor Arbiter (LA), claiming that the machines and equipment levied upon were covered by three mortgage documents in favor of the bank by UEAMI. The LA denied Metrobank’s third-party claim. Despite the pendency of appeal from the decision of the LA to the NLRC, the auction sale of the properties was carried out on Jan. 27, 2003.
The NLRC affirmed the order of the LA. Metrobank elevated the case to the Court of Appeals (CA) via a petition for certiorari. It argued that its third-party claim was denied by the LA without the benefit of a hearing. The CA dismissed the petition, ruling that under the Rules of Procedure of the NLRC, the LA was not obligated to conduct a hearing before deciding the claim. Did the CA commit a reversible error?
Ruling: No.
Petitioner’s main argument concerns the supposed failure of the LA to conduct an evidentiary hearing before resolving the third-party claim. Petitioner insists that its right to due process was violated, because such a hearing is required under Rule IV, Section 2 of the 1993 Manual. In support of its assertion, it cites Jang Lim v. CA, in which this Court supposedly applied the 1993 Manual, instead of the contradictory provisions of the 2002 NLRC Revised Rules of Procedure (2002 NLRC Rules).
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It must be emphasized that the amended provision gave the LA the discretion to determine whether additional evidence needed to be presented before the third-party claim could be resolved. Since the claimant was already required to submit proof of his alleged title to the property, the LA was allowed to decide the claim based only on the evidence submitted. Here, the LA decided that no further hearing was necessary, given the failure of Metrobank to submit proof of its claim to the properties. As will be further discussed, the Court finds no reason to overturn this conclusion.
We likewise find no merit in the assertion that petitioner was denied due process. The decision of the LA not to conduct a formal evidentiary hearing before resolving the case was justified, as the conduct of those hearings is not mandatory in all instances, particularly in administrative proceedings. At its core, due process simply means giving both parties a fair and reasonable opportunity to be heard or to explain their side of the controversy.
Here, Metrobank was clearly granted this opportunity through the written submissions it presented to the LA. That these submissions supposedly failed to include all the pieces of evidence it intended to present is entirely its fault.
In any case, Metrobank was given additional opportunities to argue its case and present its evidence before the NLRC and the CA. These subsequent proceedings were more than enough to rectify any alleged procedural flaw and satisfy the requirements of due process. (Sereno, C.J., SC 1st Division, Cameron Granville 3 Asset Management, Inc. vs. UE Monthly Associates, UEAMI Workers Union NFL and Alfredo Basi, G.R. No. 181387, Sept. 5, 2016).