Unicraft Industries International Corporation vs. Court of Appeals G.R. No. 134903. January 16, 2002 YNARES-SANTIAGO, J.

Facts Petitioner opened a branch in Lapu-Lapu City to which private respondents (ease of petitioner) were transfer. Due to the failure to comply with some legal requirements for its business operation, that branch was rendered closed and private respondents were dismissed. A complaint for illegal dismissal and payment of benefits was filed and submitted for voluntary arbitration. For failure of petitioners to appear and present evidence, the voluntary arbitrator rendered a decision in favor of respondents. Petitioners elevated the case to the Court of Appeals and the case was remanded to the voluntary arbitrator to give petitioners a chance to prove their case. The voluntary arbitrator claimed that he lost jurisdiction over the case upon rendition of the judgment. The Court of Appeals rendered a resolution allowing an execution of the award or separation pay and attorneys fees.

Issues 1. Can the voluntary arbitrator review its judgment? 2. Was the decision of the voluntary arbitrator void? Held 1.) Yes. When there is a violation of due process, judgments of voluntary arbitrators may be reviewed. It is clear that the petitioners were unable to present evidence as evident from the stipulation entered into by the parties and submitted to the CA. such was an acknowledgment that the proceedings before the VA had not been completed. While under the law, decisions, of voluntary arbitrators are accorded finality, the same may still be subject to review, such as here where there was a violation of petitioners right to due process and to be heard.

2) Yes. The decision of the voluntary arbitrator in this case was void in this case for the petitioners were not given notice to appear at the scheduled hearing until it was too late; such was a violation of their constitutional right and has the effect of rendering the judgment null and void. It is a cardinal rule in law that the decision or judgment is fatally defective. If rendered in violation of a party-litigants right to due process. Even the procedural guidelines in the Conduct of Voluntary Arbitration Proceedings require that the arbitrator should provide the parties adequate opportunities to be heard. Thus, it was grave abuse of discretion for the CA to order the execution of the award of separation pay without giving the petitioners opportunity to present evidence.