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IBM PHILIPPINES v. NLRC

This case has been cited 5 times or more.

	GR No. 174649 2008-09-26	LEOPOLDO JEREMIAS v. ESTATE OF LATE IRENE P. MARIANO CHICO-NAZARIO, J.
In contrast, respondent Estate presents a public document, the Subdivision Plan of respondent's lands covered under TCTs No. 6886 (Annex "D") and No. 6887 (Annex "C"), to advance its position that Leopoldo and Ruben are not its tenants. Although the unsigned subdivision plans presented by respondent Estate before the PARAD were evidence brushed aside by the DARAB as mere scraps of paper, reasoning that the same were not signed by the proper authorities, respondent nonetheless was able to submit before the DARAB the signed subdivision plans. The basic precept in this jurisdiction is that in administrative proceedings, such as the instant case, administrative agencies are not bound by the technical rules of procedure and evidence in the adjudication of cases.[18] Offering additional evidence on appeal and admitting the same in administrative proceedings has been sanctioned by this Court.[19] In this case, as respondent was able to present the signed and approved subdivision plans issued by the Bureau of Lands before the DARAB, said evidence can be fully considered in resolving the instant case.
	GR NO. 150171 2007-07-17	ACEBEDO OPTICAL v. NLRC CHICO-NAZARIO, J.
Herein, to our mind, petitioners have not sufficiently shown that private respondent had willfully disobeyed the company rules and regulations respecting absences and tardiness. The cause for the termination of private respondent's employment was not simply habitual tardiness and/or absenteeism. Petitioners have alleged time and again that the basis upon which the dismissal of private respondent was anchored was breach or violation of company policy. It was their contention that private respondent's habitual tardiness and/or absences were in violation of petitioner company's rules and regulations. Ironically, though petitioners referred to their company policies, they never presented a copy of these in evidence except in their Motion for Reconsideration - too late in the day. Being the basis of the charge against private respondent, it is without doubt the best evidence available to substantiate the allegations. The purpose of the rule requiring the production of the best evidence is the prevention of fraud, because if a party is in possession of such evidence and withholds it, and seeks to substitute inferior evidence in its place (or none at all save for mere allegation), the presumption naturally arises that the better evidence is withheld for fraudulent purposes which its production would expose and defeat.[32]
	GR Nos. 164684-85 2005-11-11	PHILIPPINE LONG DISTANCE TELEPHONE COMPANY v. ANTONIO Q. TIAMSON CALLEJO, SR., J.
The decisions of this Court, while adhering to a liberal view in the conduct of proceedings before administrative agencies, have nonetheless consistently required some proof of authenticity or reliability as a condition for the admission of documents.[47] Absent any such proof of authenticity, the printout of the CAMA tape should be considered inadmissible, hence, without any probative weight.
	GR NO. 158684 2005-05-16	PATERNO S. MENDOZA v. SAN MIGUEL FOODS CALLEJO, SR., J.
By admitting the position paper of the respondents and its appendages, the NLRC did not thereby condone the lackadaisical attitude of the former counsel of the respondents. Neither was the petitioner deprived of his right to due process when the NLRC admitted the respondents' position paper and its appendages. It bears stressing that in their position paper, the respondents merely rebutted the position paper of the petitioner and appended thereto corporate records including the quitclaim executed by the petitioner. Moreover, the petitioner filed a motion for the reconsideration of the decision of the NLRC but failed, even on an abundantia ad cautelam basis, to submit any evidence to rebut the position paper and evidence of the respondents. He again failed to do so when he filed his petitions in the CA and in this Court. In IBM Philippines, Inc. v. NLRC,[20] the Court ruled that:In spite of this finding, petitioners failed to adduce additional evidence when they moved for a reconsideration of the NLRC decision or when they filed the instant petition. Despite the opportunities afforded them, petitioners failed to substantiate their allegations. Neither have they shown sufficient reasons to convince this Court that, if the case were to be remanded to the arbiter for a formal hearing, they would be able to present evidence which they could not have presented during the initial stages of this case. As we held in Megascope General Services v. NLRC:
	GR No. 127469 2004-01-15	PHILIPPINE BANKING CORPORATION v. CA CARPIO, J.
The purpose of the rule requiring the production of the best evidence is the prevention of fraud.[41] If a party is in possession of evidence and withholds it, and seeks to substitute inferior evidence in its place, the presumption naturally arises that the better evidence is withheld for fraudulent purposes, which its production would expose and defeat.[42]