First Issue: Trial is Not Indispensable in Administrative Due Process Petitioners claim that Respondent Commission gravely abused its discretion in upholding the POEAs decision, which was based on the position papers and documents submitted by the parties in view of a motion for trial which remained unacted upon. They insist that a hearing was an indispensable condition before a judgment could be rendered in this case. We do not agree. Although bound by law and practice to observe due process, administrative agencies exercising quasi-judicial powers are nonetheless free from the rigidity of certain procedural requirements. As applied to these proceedings, due process requires only an opportunity to explain ones side.xiii[13] In labor cases, this Court has consistently held that due process does not necessarily mean or require a hearing, but simply an opportunity or a right to be heard. The requirements of due process are deemed to have been satisfied when parties are given the opportunity to submit position papers.xiv[14] The holding of an adversarial trial is discretionary on the labor arbiter and the parties cannot demand it as a matter of right.xv[15] More often than not, a litigant may be heard more creditably through pleadings than through oral arguments. In administrative proceedings, technical rules of procedure and evidence are not strictly applied; administrative due process cannot be fully equated with due process in its strict judicial sense.xvi[16] Due process was designed to afford an opportunity to be heard, and an actual verbal hearing need not always be held.xvii[17] The necessity of conducting a hearing is addressed to the sound discretion of the labor arbiter. These rules equally apply to cases filed with the Philippine Overseas Employment Administration Adjudication Office. Section 6 of Rule III, Book VII of the POEA Rules and Regulations of 1991xviii[18] categorically states that proceedings before a POEA hearing officer is non-litigious, although they are still subject to the requirements of due process.xix[19] Under the POEA Rules in forcexx[20] at the time the complaint was filed, summary judgments in which the pleadings, affidavits and evidence submitted are sufficient to render a decision -- are allowed under Section 4.xxi[21] Where the parties fail to agree on an amicable settlement and summary judgment is not appropriate, a judgment based on position papers may be resorted to under Section 5.xxii[22] Where there are complicated factual issues involved which cannot be resolved through such means, the hearing officer may direct the parties to submit suggested written clarificatory questions to be propounded to the party concerned.xxiii[23] Applied to this particular case, it is undeniable that petitioners were given their chance to be heard. Their answer, position paper and supporting documents had become parts of the records and were considered accordingly by the POEA administrator and by the Respondent Commission in rendering their respective decisions. Furthermore, petitioners did not deem it necessary to ask the POEA Adjudication Office to conduct a hearing. It was the private respondent who moved for a full-blown trial. Although they did not oppose the motion, they did not concur with it either. Their silence was not an assent to the motion or an argument showing its necessity. Rather, it was an