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Also, the matters contained in the following were written in accordance with the law, rules, and jurisprudence prevailing at the time of writing and posting, and do not include any future developments on the subject matter under discussion.
AT A GLANCE:
“All doubts in the implementation and interpretation of the provisions of this Code, including its implementing rules and regulations, shall be resolved in favor or labor.” (Article 4, Labor Code)
“[The] Rules shall be liberally construed to carry out the objectives of the Constitution, the Labor Code of the Philippines and other relevant legislations, and to assist the parties in obtaining just, expeditious and inexpensive resolution and settlement of labor disputes.” (Section 2, 2011 NLRC Rules of Procedure, as amended.)
“The law in protecting the rights of the employees, authorizes neither oppression nor self-destruction of the employer. It should be made clear that when the law tilts the scales of justice in favor of labor, it is in recognition of the inherent economic inequality between labor and management. The intent is to balance the scales of justice; to put the two parties on relatively equal positions. There may be cases where the circumstances warrant favoring labor over the interests of management but never should the scale be so tilted if the result is an injustice to the employer.” (Federico Ledesma, Jr. v. National Labor Relations Commission, G.R. No. 174585, October 19, 2007)
“Justitia nemini neganda est”
(Justice is to be denied to none.)
The 1987 Constitution affirms labor as a primary socio-economic force. Thus, the State shall protect the rights of workers and promote their welfare. (Section 18, Article II)
The law further says:
“The State shall afford full protection to labor. local and overseas, organized and unorganized, and promote full employment and equality of employment opportunities for all.” (Section 18, Article XIII, 1987 Constitution)
The Labor Code provides that:
“All doubts in the implementation and interpretation of the provisions of this Code, including its implementing rules and regulations, shall be resolved in favor or labor.” (Article 4, Labor Code)
Jurisprudence says:
“The measures embedded in our legal system which accord specific protection to labor stems from the reality that normally, the laborer stands on unequal footing as opposed to an employer. Indeed, the labor force is a special class that is constitutionally protected because of the inequality between capital and labor.
In fact, labor proceedings are so informally and, as much as possible, amicably conducted and without a real need for counsel, perhaps in recognition of the sad fact that a common employee does not or have extremely limited means to secure legal services nor the mettle to endure the extremely antagonizing and adversarial atmosphere of a formal legal battle.
Thus, in the common scenario of an unaided worker, who does not possess the necessary knowledge to protect his rights, pitted against his employer in a labor proceeding, xxx. As an additional aid therefore, a liberal interpretation of the technical rules of procedure may be allowed if only to further bridge the gap between an employee and an employer.” (Ariel Reyes v. Rural Bank of San Rafael, Inc., G.R. No. 230597, March 23, 2022)
“[The] Rules shall be liberally construed to carry out the objectives of the Constitution, the Labor Code of the Philippines and other relevant legislations, and to assist the parties in obtaining just, expeditious and inexpensive resolution and settlement of labor disputes.” (Section 2, 2011 NLRC Rules of Procedure, as amended.)
This liberal interpretation stems from the mandate that the workingman’s welfare should be the primordial and paramount consideration. (Fernando Manaya v. Alabang Country Club, Inc., G.R. No. 168988, June 19, 2007)
In a long line of case laws, the protection afforded to labor is not always absolute. It has certain limitations. As such, not all labor disputes are decided in favor of labor.
Jurisprudence says:
“The protection of the rights of workers cannot justify disregard of relevant facts in the construction of the text and applicable rules in the construction of the text and applicable rules in order to arrive at a disposition in favor of an employee.” (Philippine Airlines, Inc. v. National Labor Relations Commission, G.R. No. 87698, September 24, 1991)
“Courts cannot render decisions on the basis of sympathy for the workingmen at the expense of the employer.” (Caltex Philippines, Inc. v. Philippine Labor Organization, G.R. No. L-5206, April 29, 1953)
“In carrying out and interpreting the Labor Code’s provisions and its implementing regulations, the working man’s welfare should be the primordial and paramount consideration. This kind of interpretation give meaning and substance to the liberal and compassionate spirit of the law as provided for in Article 4 of the [Labor] Code. The policy is to extend the decree’s applicability to a greater number of employees to enable them to avail of the benefits under the law, in consonance with the State’s avowed policy to give maximum aid and protection to labor.” [AZUCENA, Cesario, The Labor Code with Comments and Cases (2010), p. 26, cited in the case of Ariel Reyes v. Rural Bank of San Rafael, Inc. (G.R. No. 230597, March 23, 2022)]
This is not to say however that every labor dispute will be automatically decided in favor of labor.
Jurisprudence says:
“Protection to labor and resolution of doubts in favor of labor cannot be pursued to the point of deliberately committing a miscarriage of justice. The right to obtain justice is enjoyed by all members of society, rich or poor, worker or manager, alien or citizen. Justice belongs to everyone. It is not to be blinded or immobilized by the fact of one’s being economically underprivileged.” (Ariel Reyes v. Rural Bank of San Rafael, Inc., G.R. No. 230597, March 23, 2022)
In certain cases, a liberal approach to the rules may be had even if it favors the employer. Such allowance, however, must be measured against standards stricter than that imposed against the worker, and only in compelling and justified cases where the employer will definitely suffer injustice should such liberal interpretation be disallowed. (Ariel Reyes v. Rural Bank of San Rafael, Inc., Ibid.)
“The law in protecting the rights of the employees, authorizes neither oppression nor self-destruction of the employer. It should be made clear that when the law tilts the scales of justice in favor of labor, it is in recognition of the inherent economic inequality between labor and management. The intent is to balance the scales of justice; to put the two parties on relatively equal positions. There may be cases where the circumstances warrant favoring labor over the interests of management but never should the scale be so tilted if the result is an injustice to the employer.” (Federico Ledesma, Jr. v. National Labor Relations Commission, G.R. No. 174585, October 19, 2007)
Related Articles:
Due Process in Labor Proceedings
Ensuring Due Process: What should the First Written Notice contain?
Ensuring Due Process: What should the Second Written Notice contain?
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