Valladolid v Inciong; GR No. L-52364; 25 Mar 1983; 121 SCRA 205

FACTS:
Petitioner Ricardo Valladolid was caught in an entrapment scheme effected by JRM & Co. Inc., owner and operator of Copacobana Apartment-Hotel on suspicious that he is relaying confidential business information to competitor Tropicana Apartment-Hotel. Subsequently, he went on a leave of absence. His first two requests for a five-day vacation leave and a fifteen-day sick leave were approved. However, his 30-day sick leave was not granted. He filed a complaint for illegal dismissal with vacation and sick leave pay with the NLRC when he was refused admittance upon his return. On 28 Feb 1979, JRM filed an application for clearance with the Ministry of Labor for willful breach of trust and gross neglect of duty.

ISSUE(S):
Whether or not respondent Inciong violated Section 9, Article X of the Constitution in failing to state the facts and conclusion of law upon which his order was based.

HELD:
NO. Section 9, Article X of the Constitution applies to decisions of courts of records. The Ministry of Labor is an administrative body with quasi-judicial functions. Section 5, Rule XIII, Book V, Rules and Regulations Implementing the Labor Code states that proceedings in the NLRC shall be non-litigious and summary in nature without regard to legal technicalities obtaining in courts of law. As the Deputy Minister was in full accord with the findings of fact and the conclusions of law drawn from those facts by the Regional Director, there was no necessity of discussing anew the issues raised therein.

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Category: Legal Chyme

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