Labor Relations v Standards He was informed that his services was no
longer required, without any reason.
Labor Relations- refers to the interactions
between employer and employees or their - EE alleged illegally forcibly and
representatives and the mechanism by which illegally dismissed
the standards and other terms and conditions - ER alleged that EE was employed
of employment are negotiated, adjusted and by First Staffing Network
enforced. Corporation> LEGITIMATE JOB
 right to self-organization
 collective bargaining and DECISIONS:
1. LABOR ARBITER- IN favor of
 peaceful concerted activities Manaya
including the right to strike in 2. NLRC- DISMISSED appeal, filed
accordance with law out of time
 participate in policy and
decision-making processes ACC is now contending that NLRC
affecting their rights and should have liberally interpreted and
benefits as may be provided applied the rules, allowing them to file the
by law. appeal even beyond the reglementary
Labor Standards- refers to the minimum
terms and conditions of employment to which Issue: Should the NLRC allow ACC to
employees are legally entitled and with which file its Appeal even beyond the
employers must comply. reglementary period?

o Tenure Ruling: No. Court will only allow the
o Humane conditions liberal interpretation of the Rules when
there is an extraordinary circumstance
o Living wage
that justify deviation from its stringent
Labor standards and labor relations
actually intertwine; they are not mutually In this case no extraordinary existed. It
exclusive. is a basic and irrefragable rule that in
carrying out and in interpreting the
provisions of the Labor Code and its
implementing regulations, the
Manaya vs Alabang Country Club
workingman’s welfare should be the
G.R. 168988 June 19, 2007 primordial and paramount consideration.
The interpretation herein made gives
Topic: Liberal Construction
meaning and substance to the liberal and
Facts: Manaya (maintenance helper to compassionate spirit of the law
company’s electrician) was hired by enunciated in Article 4 of the Labor Code
Alabang Country Club (ACC)(Employer). that "all doubts in the implementation and
interpretation of the provisions of the
Labor Code including its implementing the law contemplates when it
rules and regulations shall be resolved in mandated a liberal treatment in favor
favor of labor." of the working man.
- [respondent] complied with the due
The NLRC is not bound by the technical process requirement
rules of procedure and is allowed to be
liberal in the interpretation of rules in
deciding labor cases. However, such SC Ruling: IN FAVOR OF EE –
liberality should not be applied in the
Interpreted broadly
instant case as it would render futile the
very purpose for which the principle of Article 277(b) of the Labor Code provides that, in
liberality is adopted. The liberal cases of termination for a just cause, an
interpretation in favor of labor stems employee must be given "ample opportunity to
from the mandate that the be heard and to defend himself." Thus, the
workingman’s welfare should be the opportunity to be heard afforded by law to the
primordial and paramount employee is qualified by the word "ample" which
consideration. ordinarily means "considerably more than
adequate or sufficient." In this regard, the phrase
This Court has repeatedly ruled that
"ample opportunity to be heard" can be
delay in the settlement of labor cases
reasonably interpreted as extensive enough to
cannot be countenanced. Not only does
cover actual hearing or conference.
it involve the survival of an employee and
his loved ones who are dependent on
him for food, shelter, clothing, medicine To confine it to a single rigid proceeding such
and education; it also wears down the as a formal hearing will defeat its spirit.
meager resources of the workers to the
point that, not infrequently, they either In sum, the following are the guiding
give up or compromise for less than what principles in connection with the hearing
is due them. requirement in dismissal cases:

(a) "ample opportunity to be heard" means
any meaningful opportunity (verbal or
MAULA v XIMEX DELIVERY written) given to the employee to answer the
charges against him and submit evidence in
EE: Operation staff> Illegally dismissed support of his defense, whether in a hearing,
- Serious misconduct conference or some other fair, just and
- Willful disobedience reasonable way.
- 3 MEMORANDA for 3 different
(b) a formal hearing or conference becomes
mandatory only when requested by the
Decisions: employee in writing or substantial
evidentiary disputes exist or a company rule
1. LABOR ARTIBER – in favor of EE or practice requires it, or when similar
2. NLRC – affirmed in TOTO circumstances justify it.
Condoning his behavior is not what
(c) the "ample opportunity to be heard" expeditious settlement of labor or
standard in the Labor Code prevails over the industrial disputes;
"hearing or conference" requirement in the 6. To ensure a stable but dynamic and
implementing rules and regulations.37 just industrial peace; and
7. To ensure the participation of workers
No ample opportunity to be heard was also
in decision and policy-making
accorded to petitioner
processes affecting their rights, duties
and welfare.

NCC: Art. 1700. The relations between
capital and labor are not merely contractual. To encourage a truly democratic method of
They are so impressed with public interest regulating the relations between the
that labor contracts must yield to the common employers and employees by means of
good. Therefore, such contracts are subject to agreements freely entered into through
the special laws on labor unions, collective collective bargaining, no court or
bargaining, strikes and lockouts, closed shop, administrative agency or official shall have
wages, working conditions, hours of labor the power to set or fix wages, rates of pay,
and similar subjects. hours of work or other terms and conditions
of employment, except as otherwise provided
under this Code. (As amended by Section 3,
LC: Art. 211. Declaration of Policy. Republic Act No. 6715, March 21, 1989)
It is the policy of the State:
1. To promote and emphasize the GM v CUAMBOT
primacy of free collective bargaining
and negotiations, including voluntary 1. LA de VERA- in favor of
arbitration, mediation and CUAMBOT > payslips and
conciliation, as modes of settling resignation were prepared by only
labor or industrial disputes; one person (not cuambot)
2. To promote free trade unionism as an 2. NLRC – upheld GM’S contention
instrument for the enhancement of that LA is not a handwriting expert
democracy and the promotion of and remanded the case to LA
social justice and development; PORTILLIO (re-raffled)
3. To foster the free and voluntary a. LA- dismissed the case for
organization of a strong and united lack of merit; bare allegations
labor movement; of CUAMBOT
4. To promote the enlightenment of 3. NLRC- dismissed for lack of merit
workers concerning their rights and 4. CA- reversed the ruling of NLRC
obligations as union members and as
5. To provide an adequate SC RULING: Favor to CUAMBOT
administrative machinery for the
 the rule is that all doubts in the therefore subject to the police power of
implementation and the the State.
interpretation of the Labor Code
shall be resolved in favor of - project could refer to a particular
labor job or undertaking that is within
- doubts exist between the evidence
the regular or usual business of
presented by the employer and the
employee, the scales of justice must the employer company, but which
be tilted in favor of the latter is distinct and separate, and
(Nicario v NLRC) identifiable
- project could refer to a particular
job or undertaking that is within
the regular or usual business of
LEYTE v PNOC the employer company, but which
- UNION MEMBERS ARE NOT is distinct and separate, and
REGULAR employees identifiable

1. NLRC- in favor PNOC
2. CA- affirmed


Article 280 of the Labor Code,
as worded, establishes that the nature
of the employment is determined by
law, regardless of any contract
expressing otherwise. The supremacy
of the law over the nomenclature of the
contract and the stipulations contained
therein is to bring to life the policy
enshrined in the Constitution to afford
full protection to labor. Thus, labor
contracts are placed on a higher plane
than ordinary contracts; these are
imbued with public interest and