GR 87449; (January, 1990) (Digest)
G.R. No. 87449 ; January 23, 1990
SOUTH MOTORISTS ENTERPRISES, petitioner, vs. ROQUE TOSOC, ET AL., and HON. SECRETARY OF LABOR AND EMPLOYMENT, respondents.
FACTS
In January 1983, forty-six workers filed complaints against petitioner South Motorists Enterprises for non-payment of emergency cost of living allowances before the Naga City District Office of the then Ministry of Labor. The District Labor Officer issued a Special Order for an inspection of employment records. During the inspection, petitioner failed to present the records, alleging they were at the main office in Manila. The case was set for several conferences, but petitioner repeatedly requested postponements, citing the need to locate voluminous records and its lawyer’s schedule. After petitioner’s final requested extension lapsed without submission, the Labor Regulation Officers submitted an Inspection Report. Based on this, a Labor Officer issued an Order directing petitioner to pay the workers a total of P184,689.12. Petitioner’s motions for reconsideration were denied by the Labor Officer and, ultimately, by the Secretary of Labor and Employment.
ISSUE
Whether the Regional Director had jurisdiction to award the money claims, or if such jurisdiction belonged exclusively to the Labor Arbiter.
RULING
The Supreme Court ruled that jurisdiction depends on the nature and amount of the claim, as delineated by Articles 129 and 217 of the Labor Code, as amended by Republic Act No. 6715 . These amendments, being curative, applied retroactively. Article 129 empowers Regional Directors to hear and decide, through summary proceedings, claims for recovery of wages and other monetary benefits, provided: (1) the claim arises from an employer-employee relationship; (2) the claimant does not seek reinstatement; and (3) the aggregate money claim of each employee does not exceed P5,000.00. For claims exceeding P5,000.00 per employee, Article 217 grants original and exclusive jurisdiction to the Labor Arbiter.
Applying this to the case, the Court found that the total award of P184,689.12 comprised individual claims. The awards to eleven specific workers each exceeded the P5,000.00 threshold. Consequently, the Regional Director lacked jurisdiction over these larger claims, which properly fell under the Labor Arbiter’s authority. However, the Regional Director validly exercised jurisdiction over the claims of the other thirty-five workers, as each did not exceed P5,000.00. The Court also held that petitioner was afforded due process, as its own failure to present evidence despite multiple opportunities constituted a waiver of its right to controvert the claims. The award was thus modified, affirming the validly adjudicated claims and remanding the eleven excessive claims to the Labor Arbiter for proper proceedings.