Procopio was dismissed from employment for stealing his co-employee Raul’s watch. Procopio filed a complaint for illegal dismissal. The Labor Arbiter ruled in Procopio’s favor on the ground that Raul’s testimony was doubtful, and, therefore, the doubt should be resolved in favor of Procopio. On appeal, the NLRC reversed the ruling because Article 4 of the Labor Code – which states that all doubts in the interpretation and implementation of the provisions of the Labor Code, including the implementing rules and regulations, shall be resolved in favor of labor – applied only when the doubt involved the “implementation and interpretation” of the Labor Code; hence, the doubt, which involved the application of the rules on evidence, not the Labor Code, could not necessarily be resolved in favor of Procopio. Was the reversal correct? Explain your answer. (3%)
Suggested Answer:
No. Answer
Under the Labor Code, Article 4 provides that all doubts in the implementation and interpretation of the provisions of the Code, including its implementing rules and regulations, shall be resolved in favor of labor. Rule
Further, under both the Labor Code and the 2011 NLRC Rules of Procedure, technical rules of procedure and evidence in courts are not binding on labor cases before the Labor Arbiter and the NLRC. Rule
Applying the foregoing, Article 4 of the Labor Code covers doubts involving evidence in a labor case as technical rules of procedure are not binding. The provision is thus not limited to the implementation and interpretation of the Labor Code. Apply
Thus, the NLRC incorrectly reversed the Labor Arbiter. Conclusion
