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Cralaw Virtua1aw Lib Rary

This document is a syllabus from a Supreme Court case between Cebu Stevedoring Co., Inc. and the Regional Director of Labor regarding two employees, Arsenio Gelig and Maria Luz Quijano. The syllabus outlines 4 key points: 1) Due process requires notice and an opportunity to be heard before depriving someone of their rights. 2) Any inadequacy in procedural due process from trial proceedings can be remedied by appellate review. 3) One of the most important state policies is promoting social justice and protecting worker's rights and welfare. 4) Findings of quasi-judicial agencies that have expertise in specific matters, like labor, are generally

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0% found this document useful (0 votes)
56 views1 page

Cralaw Virtua1aw Lib Rary

This document is a syllabus from a Supreme Court case between Cebu Stevedoring Co., Inc. and the Regional Director of Labor regarding two employees, Arsenio Gelig and Maria Luz Quijano. The syllabus outlines 4 key points: 1) Due process requires notice and an opportunity to be heard before depriving someone of their rights. 2) Any inadequacy in procedural due process from trial proceedings can be remedied by appellate review. 3) One of the most important state policies is promoting social justice and protecting worker's rights and welfare. 4) Findings of quasi-judicial agencies that have expertise in specific matters, like labor, are generally

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G.R. No. L-54285. December 8, 1988.

CEBU STEVEDORING CO., INC., Petitioner, v. THE HONORABLE REGIONAL DIRECTOR/MINISTER


OF LABOR, ARSENIO GELIG and MARIA LUZ QUIJANO, Respondents.

Valentin A. Zozobrado for Petitioner.

Silvino G. Maceren, Jr. for Private Respondents.

Office of the Solicitor General for public Respondent.

SYLLABUS

1. CONSTITUTIONAL LAW; BILL OF RIGHTS; DUE PROCESS REQUIREMENT; NOTICE AND OPPORTUNITY TO
BE HEARD. — We agree that no rule is better established, under the due process clause of the Constitution,
than that which requires notice and the opportunity to be heard before any person can be lawfully deprived
of his rights. The right to be heard, as a preliminary step essential to the rendition of an enforceable
judgment, constitutes a basic element of the constitutional requirement of due process of law.

2. REMEDIAL LAW; APPEAL; CURES INADEQUACY IN ANY ALLEGED DENIAL OF PROCEDURAL DUE PROCESS.
— The entire record of the case was reviewed and duly considered on appeal to the Labor Minister, which
appellate proceeding remedied any inadequacy in the procedural due process with which the trial
proceedings are being faulted. Thus, We have consistently adhered to the decisional rule that appellate
review is curative in character on the issue of an alleged denial of due process for lack of a hearing in the
case.

3. CONSTITUTIONAL LAW; PROMOTION OF SOCIAL JUSTICE, SPECIFICALLY PROTECTION TO LABOR; MOST


IMPORTANT STATE POLICY. — This Court has never lost sight of the fact that one of the most important and
significant State policies, enshrined in the present Constitution as it was in its two predecessors, is the
promotion of social justice in all phases of national development, specifically the protection of the rights of
workers and the promotion of their welfare. It was in the light of this concern in the fundamental law and
the jurisprudence thereon that the Labor Code was enacted, with a specific declaration of its basic policy
that — "The State shall afford protection to labor, promote full employment, ensure equal work
opportunities regardless of sex, race or creed, and regulate the relations between workers and employers.
The State shall assure the rights of workers to self-organization, collective bargaining, security of tenure,
and just and human conditions of work." cralaw virtua1aw l ib rary

4. LABOR LAW; MINISTER OF LABOR; FINDINGS OF QUASI-JUDICIAL AGENCIES GENERALLY ACCORDED


NOT ONLY RESPECT BUT WITH FINALITY. — We agree with the Regional Director that private respondents
could not be considered probationary employees because they were already well-trained in their respective
functions. This conclusion is further bolstered by the factual findings of the Labor Minister that said order of
the Director was supported by substantial evidence. As stressed by the Solicitor General, while private
respondents were still with the CCAS they were already clerks. Respondent Gelig had been a clerk for CCAS
for more than ten (10) years, while respondent Quijano had slightly less than ten (10) years of service. They
were, therefore, not novices in their jobs but experienced workers. On this particular issue, it is perhaps
timely to consider well-settled principles involving decisions of administrative agencies. Findings of quasi-
judicial agencies which have acquired expertise because their jurisdiction is confined to specific matters are
generally accorded not only respect but, at times, even finality where such findings are supported by
substantial evidence, and judicial review by Us is limited to issues of jurisdiction or grave abuse of
discretion.

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