G.R. Nos. L-39032 and L-39134 December 18, 1974
ENJAY, INC. (HOTEL INTER-CONTINENTAL MANILA) and GRAHAM K. L. JEFFREY, petitioners, vs. COURT OF INDUSTRIAL RELATIONS and SAMAHAN NG MGA MANGGAGAWA SA HOTEL INTER-CONTINENTAL MANILA, respondents.

FACTS

The Samahan ng Mga Manggagawa sa Hotel Inter-Continental Manila (Union) filed two cases against the Hotel Inter-Continental Manila (Hotel) in the Court of Industrial Relations (CIR). The first, Case No. 3448-V, involved monetary claims for overtime pay, wage differentials, and service charges. The second, Charge No. 5657, was an unfair labor practice charge alleging the Hotel deprived employees of their 1973 Christmas bonus due to union activities. The Hotel moved to dismiss both cases, arguing the CIR lacked jurisdiction. It invoked Presidential Decree No. 21, which conferred original and exclusive jurisdiction over all employer-employee relations disputes to the National Labor Relations Commission (NLRC). The CIR, through different judges, denied the motions to dismiss and subsequent motions for reconsideration, prompting the Hotel to file this petition for certiorari.
During the pendency of the petition, significant legal developments occurred. The Union admitted that Charge No. 5657 had been terminated through arbitration. Furthermore, the Labor Code took effect on November 1, 1974, abolishing both the CIR and the old NLRC. The Union, in its memorandum, conceded that the sole issue was the CIR’s jurisdiction over the pending monetary claims in Case No. 3448-V. It prayed that, should the Court find the CIR lacked jurisdiction, the case be transferred to the new NLRC created under the Labor Code pursuant to its transitory provisions.

ISSUE

Whether the Court of Industrial Relations had jurisdiction to entertain Case No. 3448-V involving monetary claims filed after the effectivity of Presidential Decree No. 21.

RULING

The Supreme Court granted the petition, ruling that the CIR acted without jurisdiction. The legal logic is anchored on the explicit jurisdictional transfer effected by Presidential Decree No. 21, dated October 24, 1972. This decree vested original and exclusive jurisdiction over “all matters involving employee-employer relations” in the National Labor Relations Commission. Since Case No. 3448-V, involving claims for overtime and wage differentials, is indisputably a matter of employer-employee relations, it fell squarely within the NLRC’s jurisdiction from the time of the decree’s effectivity. The CIR’s denial of the motion to dismiss was therefore a grave abuse of discretion, as it acted coram non judice (without authority). Consequently, the challenged CIR orders and resolutions were set aside. However, giving effect to the transitory provisions of the new Labor Code (Article 338, later renumbered), and granting the Union’s prayer, the Supreme Court ordered the transfer of CIR Case No. 3448-V to the new National Labor Relations Commission for proper disposition.