Heritage Hotel v. National Union (G.R. No. 178296; January 12, 2011)

CASE DIGEST: THE HERITAGE HOTEL MANILA, acting through its owner, GRAND PLAZA HOTEL CORPORATION, Petitioner, vs. NATIONAL UNION OF WORKERS IN THE HOTEL, RESTAURANT AND ALLIED INDUSTRIES-HERITAGE HOTEL MANILA SUPERVISORS CHAPTER (NUWHRAIN-HHMSC), Respondent.

FACTS: Respondents filed a petition for certification of pre-election with the DOLE. The Med-Arbiter approved the pre-election. However, the certification election was delayed, but pushed through nonetheless. Petitioner filed for cancellation of the certification due to the failure of respondent to submit its financial statements to the Bureau of Labor Relations. The Med-Arbiter still ruled in favor of respondents. Petitioner appealed the decision to the regional director of the DOLE. The Regional director still rendered a decision in favor of respondents, which prompted petitioners to appeal the decision to the director of the Bureau of Labor Relations.The director of the BLR inhibited from the issue, as he was previously the counsel of respondents. The Secretary of Labor resolved the issue in the stead of the BLR director. She ruled in favor of respondents. The petitioner filed a motion for reconsideration of the decision, but was turned down. Petitioner then filed for certiorari, challenging the jurisdiction of the DOLE Secretary. An appeal from the decision of the Regional Director is supposed to be under the jurisdiction of the BLR. Also, petitioner claims to have been deprived of due process as it was not informed of the inhibition of the BLR director.

ISSUES: [1] Is the ruling of the secretary of labor valid? [2] Was petitioner deprived of due process?

HELD: It is without question that the appeal from the decision of the regional office is within the jurisdiction of the BLR. Given the circumstances, the BLR director inhibited himself. Petitioner insists that the case should have gone to the subordinates of the BLR director. However, this happens in cases where the director is incapacitated. This does not obtain as the director merely inhibited himself. On the other hand, the Secretary of DOLE has powers of supervision and control over the BLR. As such, it may validly step into the shoes of the BLR director and resolve the issue.

The concept of due-process is different in proceedings before the courts, and before administrative agencies. For the latter, the essence is the opportunity to be heard. In this case, the petitioner was able to file a motion for reconsideration on the decision of the DOLE Secretary, albeit was denied. Petitioner was given due-process, and its contention that it was unaware of the inhibition of the BLR director is of no moment.