G.R. No. 98050
March 17, 1994
Facts
PhilPhos Movement for Progress, Inc. (PMPI), filed with the Department of Labor and Employment a petition for certification election among the supervisory employees of the petitioner. PMPI , as a supervisory union duly registered with the DOLE, was seeking to represent the supervisory employees of petitioner Philippine Phosphate Fertilizer Corporation (PHILPOS).
The petition was not opposed by petitioner PHILPOS. PHILPOS even welcomed the creation of supervisory employees’ union provided that the managerial, professional, and technical employees who are not within the definition of supervisory employees are exempted from the PMPI Supervisory Union. Mediator-Arbiter Rodolfo S. Milado issued order granting petitioner’s prayer. With this, the PMPI filed an amended petition seeking to represent not only the supervisory but also the managerial, professional, and technical employees of PHILPOS. The parties agreed to submit their respective position paper submitted for decision on the basis thereof and related documents. Thereafter, the Mediator-Arbiter issued an order granting the petition in favor PMPI. Aggrieved, the petitioner appealed the order to the Secretary of Labor which was dismissed by the latter. Hence, PMPI filed the instant petition.
PHILPOS contends that the ruling of the of the said respondents were attended by grave abuse of discretion on the ground that the petitioner was denied due process in the proceedings before respondent Mediator-Arbiter.
Issue
Whether or not the petitioner was denied due process in the proceedings before respondent Mediator-Arbiter?
Held
No. According to the Supreme Court, the essence of due process is simply an opportunity to be heard. As applied to administrative proceedings, the essence of due process is an opportunity to explain one’s side or an opportunity to seek a reconsideration of the action or ruling complained of.
In the case at bar, petitioner was not denied due process since the latter was given the opportunity to be heard when the petitioner agreed to file its position paper with the Mediator-Arbiter and to consider the case submitted for decision on the basis of the position papers filed by the parties.
Hence, the petition was denied since the petitioner was afforded due process as the latter was given opportunity to be heard through its submitted position paper.