5/19/2021 E-Library - Information At Your Fingertips: Printer Friendly Consistent with the Court's vow to render and dispense justice, we will not hesitate in relaxing procedural rules, if needed, so as not to unjustly deprive a litigant the chance to present his or her case on the merits.[18] As for the issue of illegal dismissal, petitioners invoke Section 33 of the POEA Employment Contract, alleging that Loyola was guilty of incompetence and inefficiency. According to petitioners, respondent failed to pass the criteria set by petitioners in relation to his work, which is a sufficient ground to terminate him from employment. They claim that Loyola was notified of his poor performance on board and was given the opportunity to explain when he was given the formal warning. He was notified of the schedule of the hearing and eventually notified of his termination. To prove that he was duly notified of his termination, petitioners cite the notice of termination signed by the Chief Mate, Bosun and Master on board the vessel.[19] We agree with both the NLRC and the CA that petitioners failed to discharge its burden of proving that Loyola was dismissed due to a just and authorized cause and that the twin notice requirements were complied with. The general rule is that factual findings of administrative or quasi-judicial bodies, which include labor tribunals, are accorded much respect by this Court as they are specialized to rule on matters falling within their jurisdiction especially when these are supported by substantial evidence.[20] In labor cases, the burden of proving that the termination of an employee was for a just or authorized cause lies with the employer. If the employer fails to meet this burden, the conclusion is that the dismissal was unjustified and, therefore, illegal.[21] Moreover, not only must the dismissal be for a cause provided by law, it should also comply with the rudimentary requirements of due process, that is, the opportunity to be heard and defend one's self. Thus, for dismissal to be valid, the employer must show through substantial evidence – or such amount of relevant evidence that a reasonable mind might accept as adequate to support a conclusion – that (1) the dismissal was for a just or authorized cause; and (2) the dismissed employee was afforded due process. [22] In this case, petitioners assert that Loyola's termination was due to his incompetence and inefficiency. Incompetence or inefficiency as a ground for dismissal contemplates the failure to attain work goals or work quotas, either by failing to complete the same within the allotted reasonable period, or by producing unsatisfactory results.[23] Apart from their bare allegation that Loyola was dismissed due to incompetence and inefficiency as he "failed to pass the criteria set by petitioners in relation to his work," petitioners failed to present any evidence to substantiate such claim. As noted by the NLRC and the CA, no evidence was presented to support the allegation that he was grossly and habitually neglectful of his duties that would merit his dismissal. The Court has consistently held that uncorroborated and self-serving statements of employers are sorely inadequate in meeting the required quantum of proof to discharge their burden.[24] https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66403 5/9