IMPERIAL TEXTILE MILLS, INC.

V NLRC, ANGIE MENDOZA

FACTS:
Mendoza was employed with the company since 1977 up to 1986. In the latter part of 1986, a
new management group took over Imperial Textile. Mendoza, who was on leave at the time,
found out about the changes. Her position was filled by a newcomer. Mendoza wrote to the
company “In view of the above circumstances, I deem it proper and wise to cease my
employment, but with equivalent separation pay from the company.”
On June 6, 1986, the instant complaint for illegal dismissal was filed. Complainant alleged that
she was dismissed without sufficient grounds after 14 years of service.
Imperial Textile averred that complainant voluntarily resigned and if she was terminated such
termination was due to valid and just grounds. Being a managerial employee she could be
terminated for loss of trust and confidence. Thereafter, the parties submitted their respective
position papers. Petitioner then filed a motion to dismiss alleging that: (1) private respondent's
position paper is unverified and should be stricken off the record; and (2) complainant failed to
appear despite notice, thereby depriving petitioner of its right to cross-examine her. In an order,
the labor arbiter dismissed the complaint without prejudice, on the ground that complainant's
absence deprived herein petitioner of the opportunity to cross-examine her.
On appeal, respondent commission reversed the labor arbiter holding that under Article 221 of
the Labor Code, respondent commission and the labor arbiter have the authority to decide
cases based on position papers and documents submitted by the parties without resorting to
technical rules of evidence; and that herein petitioner was not denied due process because on
the basis of the records of the case, an intelligent decision could be arrived at without resorting
to a formal hearing. The case was thereafter remanded to the labor arbiter who subsequently
rendered a decision declaring the dismissal of complainant as legally effected on the ground
that she resigned voluntarily and that her dismissal was for a valid cause, that is, loss of trust
and confidence. On appeal, respondent commission rendered its questioned decision reversing
the findings of the labor arbiter and holding that herein private respondent was illegally
dismissed.
Issues: 1.W/N the NLRC erred in rendering a decision based on the private respondent’s
unverified position paper.
2.W/N the late filing of the appeal by private respondent be detrimental to her case
Held:
1.No. Well-settled is the rule that procedural technicalities do not strictly apply to proceedings
before labor arbiters for they may avail themselves of all reasonable means to speedily
ascertain the facts of a controversy.
2. No. The general rule is that the perfection of an appeal in the manner and within the period
prescribed by law is not only mandatory but jurisdictional. Failure to conform to the rules will
render the judgment sought to be reviewed final and unappealable. Nevertheless, in some
instances, this Court has disregarded such unintended lapses so as to give due course to
appeals filed beyond the reglementary period on the basis of strong and compelling reasons,
such as serving the ends of justice and preventing a grave miscarriage thereof.