Political Law

Miguel Singson vs National Labor Relations Commission

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G.R. No. 122389 – 274 SCRA 358 – Political Law – Constitutional Law – Due Process; Administrative Bodies – May a commissioner review a case he decided when he was still an arbiter

Miguel Singson was an employee of the Philippine Air Lines (PAL). In 1991, a Japanese national alleged that Singson extorted money from her ($200.00) by accusing her of having excess baggage; and that to settle the issue, she needs to pay said amount to him. Singson was later investigated and the investigating committee found him guilty. PAL then dismissed Singson from employment. Singson then filed a case before NLRC against PAL for illegal dismissal. Labor Arbiter Raul Aquino ruled in favor of Singson as he found PAL’s side insufficient to dismiss Singson. PAL appealed to the National Labor Relations Commission (NLRC) and his case was raffled to the 2nd Division thereof.

The 2nd Division, however, was composed of Commissioners Victoriano Calaycay, Rogelio Rayala, and former Labor Arbiter Raul Aquino – same arbiter which decided Singson’s case. The commissioners deliberated on the case and thereafter¬†reversed the decision of Aquino.

Singson moved for reconsideration. This time, only Commissioners Calaycay and Rayala deliberated on the motion. The motion was denied.

ISSUE: Whether or not Singson was denied of due process.

HELD: Yes.¬†The Supreme Court ruled that Singson was denied due process. The SC held that Singson was denied due process when Aquino participated, as presiding commissioner of the 2nd Division of the NLRC, in reviewing PAL’s appeal. He was reviewing his own decision as a former labor arbiter.

Under Rule VII, Section 2 (b) of the New Rules of Procedure of the NLRC, each Division shall consist of one member from the public sector who shall act as the Presiding Commissioner and one member each from the workers and employers sectors, respectively. The composition of the Division guarantees equal representation and impartiality among its members. Thus, litigants are entitled to a review of three (3) commissioners who are impartial right from the start of the process of review.

Commissioner Aquino can hardly be considered impartial since he was the arbiter who decided the case under review. He should have inhibited himself from any participation in this case. The infirmity of the resolution was not cured by the fact that the motion for reconsideration of Singson was denied by two commissioners and without the participation of Aquino. The right of petitioner to an impartial review of his appeal starts from the time he filed his appeal. He is not only entitled to an impartial tribunal in the resolution of his motion for reconsideration. Moreover, his right is to an impartial review of three commissioners. The denial of Singson’s right to an impartial review of his appeal is not an innocuous error. It negated his right to due process.

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