WILGEN LOON, ET AL. v. POWER MASTER, INC., ET AL., G.R. NO. 189404, December 11, 2013

Labor Law; Issue of the appeal bond’s validity may be raised for the first time on appeal since its proper filing is a jurisdictional requirement. The requirement that the appeal bond should be issued by an accredited bonding company is mandatory and jurisdictional. The rationale of requiring an appeal bond is to discourage the employers from using an appeal to delay or evade the employees’ just and lawful claims. It is intended to assure the workers that they will receive the money judgment in their favor upon the dismissal of the employer’s appeal.

Labor law; A party may only adduce evidence for the first time on appeal if he adequately explains his delay in the submission of evidence and he sufficiently proves the allegations sought to be proven. In labor cases, strict adherence to the technical rules of procedure is not required. However, this liberal policy should still be subject to rules of reason and fair play.  The liberality of procedural rules is qualified by two requirements: (1) a party should adequately explain any delay in the submission of evidence; and (2) a party should sufficiently prove the allegations sought to be proven. The reason for these requirements is that the liberal application of the rules before quasi-judicial agencies cannot be used to perpetuate injustice and hamper the just resolution of the case. Neither is the rule on liberal construction a license to disregard the rules of procedure.

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