[G.R. No. 117221.

April 13, 1999]

IBM PHILIPPINES, INC., VIRGILIO L. PEA, and VICTOR V. REYES, petitioners, vs. NATIONAL LABOR
RELATIONS COMMISSION and ANGEL D. ISRAEL, respondents.

FACTS:

Petitioner IBM Philippines, Inc. (IBM) is a domestic corporation engaged in the business of selling
computers and computer services. Petitioners Virgilio L. Pea and Victor V. Reyes were ranking officers of
IBM during the period pertinent to this case.

On April 1, 1975, private respondent Angel D. Israel commenced employment with IBM as Office
Products Customer Engineer.For the next sixteen (16) years, he occupied two other positions in the
company,[2] received numerous awards,[3] and represented the company in various seminars and
conferences in and out of the country.[4]

On February 1, 1990, private respondent was assigned to the team supervised by petitioner Reyes.

On June 27, 1991, petitioner Reyes handed a letter to private respondent informing the latter that his
employment in the company was to be terminated effective July 31, 1991 on the ground of habitual
tardiness and absenteeism.

Alleging that his dismissal was without just cause and due process, private respondent filed a complaint
with the Arbitration Branch of the Department of Labor and Employment (DOLE) on July 18, 1991.

In his position paper filed on September 6, 1991, he claimed that he was not given the opportunity to be
heard and that he was summarily dismissed from employment based on charges which had not been duly
proven.

Petitioners denied private respondents claims. It was alleged that several conferences were held by the
management with private respondent because of the latters unsatisfactory performance in the company
and he was given sufficient warning and opportunity to reform and improve his attitude toward
attendance, but to their regret, he never did. It was alleged that private respondent was constantly told of
his poor attendance record and inefficiency through the companys internal electronic mail (e-mail)
system. According to petitioners, this system allows paperless or telematic communication among IBM
personnel in the company offices here and abroad.

ISSUES:

1. THE NATIONAL LABOR RELATIONS COMMISSION COMMITTED GRAVE ABUSE OF

DISCRETION TANTAMOUNT TO LACK OF JURISDICTION IN HOLDING THAT NO JUST
CAUSE EXISTS NOR WAS THERE DUE PROCESS OBSERVED IN THE DISMISSAL OF
THE PRIVATE RESPONDENT BECAUSE THE COMPUTER PRINTOUTS WHICH PROVE
JUST CAUSE AND DUE PROCESS ARE NOT ADMISSIBLE IN EVIDENCE.
2. THE NATIONAL LABOR RELATIONS COMMISSION COMMITTED GRAVE ABUSE OF
DISCRETION TANTAMOUNT TO LACK OR EXCESS OF ITS JURISDICTION IN HOLDING
THAT EVEN IF THE COMPUTER PRINTOUTS WERE ADMISSIBLE, PETITIONER FAILED
TO SATISFY DUE PROCESS.
RULING:

The petition has no merits. Petitioners argue that the computer print-outs submitted by them need not be
identified or authenticated according to the rules of procedure in regular courts in order for the same to be
admissible in evidence. They contend that technical rules of evidence do not apply to administrative/labor
cases and because of a relaxation of the rules of evidence, private respondent was in fact allowed by the
labor arbiter to adduce additional evidence even after a decision had been rendered. It is true that
administrative and quasi-judicial bodies like the NLRC are not bound by the technical rules of procedure
in the adjudication of cases. However, this procedural rule should not be construed as a license to
disregard certain fundamental evidentiary rules. While the rules of evidence prevailing in the courts of law
or equity are not controlling in proceedings before the NLRC, the evidence presented before it must at
least have a modicum of admissibility for it to be given some probative value. The Statement of Profit and
Losses submitted by Crispa, Inc. to prove its alleged losses, without the accompanying signature of a
certified public accountant or audited by an independent auditor, are nothing but self-serving documents
which ought to be treated as a mere scrap of paper devoid of any probative value. WHEREFORE, the
petition is DISMISSED and the decision of the NLRC, dated April 15, 1994, is hereby AFFIRMED.
 [G.R. No. 136211. March 31, 2005]

HEIRS OF VICENTE HIDALGO, SR., petitioners, vs. DEPARTMENT OF AGRARIAN

REFORM, respondent.
FACTS:

PD No. 27 took effect on 21 October 1972. Pursuant to this law, several parcels of land with an
aggregate area of 26.2987 hectares, more or less, owned by the late Vicente F. Hidalgo, Sr., located in
Milaor, Camarines Sur, were placed under the OLT program of the government. The petitioners herein
protested the inclusion of these parcels of land to the OLT program because, according to them, the same
had already been sold to them before their fathers death on 17 April 1979. In view of the protest, the DAR
Municipal Agrarian Reform Office conducted an investigation on the matter. The investigation found out
that the sales made by Vicente Hidalgo, Sr., to his daughters Angela Hidalgo Palacio and Dominica Hidalgo
in the year 1972 were not registered with the Register of Deeds. The protest was denied by the DAR
Regional Director for Region V in his Order dated 20 January 1992. According to the Regional Director, a
sale prior to the effectivity of PD No. 27, if not registered, does not bind the DAR or any third party. It was
also mentioned that the third sale executed in 1974 in favor of Josefina Hidalgo Bergantin was an illegal
transaction which was designed to circumvent the law.
A motion for the reconsideration of the order was filed by Dominica Hidalgo in the form of a letter. It
was denied by the DAR Regional Office for Region V in an order dated 15 June 1994.
An appeal was made to the DAR, alleging among other things, that the tenant farmers had knowledge
of the sale to the heirs of Vicente Hidalgo, Sr. This, according to the petitioners, was already equivalent to
registration.

ISSUES:

The solitary issue that should be resolved in this case is whether or not there was a valid transfer of
ownership of the subject parcels of land to the heirs of Vicente Hidalgo, Sr., thereby exempting the same
from the coverage of the OLT Program of the government pursuant to PD No. 27.

RULING:

This factual finding of the DAR is entitled to great weight. Factual findings of agencies exercising quasi-
judicial functions are accorded not only respect but even finality, aside from the consideration that this
Court is not a trier of facts. The petitioners submit that the knowledge of the tenant farmers of the sales
between Vicente Hidalgo, Sr., and his heirs over the parcels of land was already equivalent to
registration. The respondents contented that it is the act of registration that gives validity to the transfer or
creates a lien upon the land which is titled under the Torrens System.

The factual findings of the DAR is entitled to great weight. Factual findings of agencies exercising quasi-
judicial functions are accorded not only respect but even finality, aside from the consideration that this Court
is not a trier of facts. Considering that there was no factual finding that the tenant farmers had actual
knowledge of the sales between Hidalgo and his heirs, then, our pronouncement in the case of Antonio v.
Estrella where there was a finding of fact that there was prior knowledge, is inapplicable.
The factual findings of the DAR, which were not disputed nor opposed by the Court of Appeals, that
the tenant farmers had no prior knowledge of the transfer of ownership before the effectivity of PD No. 27
shall not be disturbed.

The Department of Agrarian Reform through its Secretary is hereby empowered to promulgate rules and
regulations for the implementation of this Decree. Culled from the above expositions, it is our conclusion
that the parcels of land subject of the instant case are not exempt from the coverage of the OLT program
of the government.

WHEREFORE, in view of all the foregoing, the Decision of the Court of Appeals dated 22 July 1998
and its Resolution dated 20 October 1998 are hereby AFFIRMED. Costs against the petitioners.