c. Technical Rules Not Binding

TECHNICAL RULES NOT BINDING

Concept

In proceedings before the National Labor Relations Commission (NLRC) or a Labor Arbiter, the rules of evidence prevailing in courts of law or equity are not controlling. The aim is to ascertain the facts speedily and objectively through reasonable means, without allowing technicalities of law or procedure to defeat due process. This is a rule of procedural flexibility, not a direction to disregard the facts needed to decide a claim. (Art. 221, Labor Code)¹ (Ondevilla v. De Letran, G.R. No. 278615, 29 June 2026)²

Governing provisions

Article 221 of the Labor Code directs the Commission, its members, and Labor Arbiters to use every reasonable means to determine the facts, in the interest of due process. It also permits parties to be represented by counsel while placing the proceedings at all stages under the complete control of the designated Commission officer or Labor Arbiter. (Art. 221, Labor Code)¹

Requisites / Rules

• Scope. The statutory direction applies to proceedings before the Commission or any Labor Arbiter; ordinary court rules of evidence do not control those proceedings. (Art. 221, Labor Code)¹
• Method and limit. The decision-maker must seek the facts speedily and objectively by reasonable means, without undue regard to technicalities, but always in the interest of due process. (Art. 221, Labor Code)¹
• Settlement. A Labor Arbiter must exert all efforts toward amicable settlement of a dispute within the Arbiter’s jurisdiction on or before the first hearing. The same rule applies when the Commission exercises original jurisdiction. (Art. 221, Labor Code)¹

Distinctions

Procedural flexibility before labor tribunals does not mean that every procedural requirement in a related case disappears. For example, the governing rule for a motion for reconsideration before the Commission in Oriental Shipmanagement required a motion under oath within ten calendar days from receipt and allowed only one such motion per party. Identify the applicable requirement before invoking liberal construction. (Oriental Shipmanagement Co., Inc. v. Nazal, G.R. No. 177103, 3 June 2013)³

Key doctrines

In Oriental Shipmanagement, the Court emphasized that procedural technicalities in labor cases are interpreted liberally under Article 221 to facilitate speedy and objective resolution. In PMI-Faculty and Employees Union, it held that stringent application of procedural rules should not defeat substantial justice, especially where an appeal is meritorious on its face. (Oriental Shipmanagement Co., Inc. v. Nazal)³ (Pmi-Faculty and Employees Union v. Bohol, G.R. No. 211526, 29 June 2016)⁴

Exceptions

Liberality does not supply material that is absent from the record. In Ondevilla, entitlement to collective bargaining agreement (CBA) benefits could not be established without a copy of the CBA from which the benefits and their coverage could be determined. Nor need a reviewing court consider an issue first raised at a late stage rather than brought to the lower court’s attention; fairness and due process remain controlling. (Ondevilla v. De Letran)²

Bar tip

State both halves of the rule: technical evidence rules do not control Commission or Labor Arbiter proceedings, but fact-finding must remain reasonable, objective, and consistent with due process. Do not treat liberality as a substitute for placing the basis of a claim on record. (Art. 221, Labor Code)¹ (Ondevilla v. De Letran)²