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respondent - david

employee as service manager

petitioner - buenaflor car services
pronto! auto services

implemented company policy with respect to purchase and delivery of automotive
parts and products.

Preparation of purchas order (guzman)
Review and approval - david
will give copy of purchase order to Buenaflor Car services - guzman
buenaflor will deliver the goods/supply
reception of goods - guzman
submit a copy of purchase order to del rosario - guzman
prepare request for payment to be revuewed by vasay - del rosario
once approved by del rosario, checks are prepared to be signed by any of the
David, vasay or buenaflor.

It is also a policy that the check shall be issued in the name of specific supplier
and not in cash. However, it is later brought to the attention of the company that
several checks were issued by the company bearing the word "OR CASH", hence an
investigation was conducted. Del rosario confessed that David instructed her to
insert the word "OR CASH" in the name of the payees, guzman was also ordered by
David to prepare spurious purchase orders and Caranto, Buenaflor's
messenger/driver, was directed to encash the checks. Guzman, David and Carinto were
terminated, hence they filed with the RTC an action for illegal dismissal. NLRC
found Del del rosario, Carinto and Guzman validly terminated, except David.

Issue: WON the extra-judicial confession of Del Rosario may be used against David.
Ruling: Yes.

NLRC should not have bound itself by the technical
rules of procedure as it is allowed to be liberal in the application of its rules
in deciding labor cases.44 The NLRC Rules of Procedure state that "[t]he
rules of procedure and evidence prevailing in courts of law and equity shall
not be controlling and the Commission shall use every and all reasonable
means to ascertain the facts in each case speedily and objectively, without
regard to technicalities of law or procedure