G.R. No. L-18708; November 28, 1962
HACIENDA ESPERENZA and HACIENDA CAMMISANA, Thru The Administrator, MARCELO PIJUAN, petitioners, vs. COURT OF INDUSTRIAL RELATIONS and NATIONAL SUGAR WORKERS’ UNION (PAFLU), respondents.

FACTS

The case originated from an unfair labor practice complaint filed by the National Sugar Workers’ Union against Hacienda Esperanza and Hacienda Cammisana. The complaint involved several laborers, but the appeal to the Supreme Court concerned only the claim of Salvador Vicente. Vicente, a member of the union with over thirty years of service, was dismissed in May 1956. He died during the pendency of the case before the Court of Industrial Relations (CIR).
The CIR, in its decision, found no substantial proof that Vicente’s dismissal constituted unfair labor practice, as the alleged discriminatory act occurred in 1954, two years prior to his termination. Despite this finding, the CIR, “for reasons of equity” and because the haciendas showed no valid cause for discharge, awarded separation pay to Vicente’s heirs. The haciendas appealed, contesting this award and, primarily, the jurisdiction of the CIR over the dispute.

ISSUE

The principal issue is whether the Court of Industrial Relations had jurisdiction over the unfair labor practice complaint filed by agricultural laborers against agricultural enterprises.

RULING

The Supreme Court ruled that the CIR had no jurisdiction. The legal logic hinges on the statutory delineation of jurisdiction between the CIR and the Court of Agrarian Relations (CAR). The Court emphasized that the complainants were agricultural laborers working on agricultural land, and there was no showing their tasks were “totally unconnected with agricultural operations.” Consequently, they fell outside the definition of “employee” under the Industrial Peace Act ( Republic Act No. 875 ), which governed the CIR’s jurisdiction over labor disputes.
The Court, citing its precedent in Santos v. Court of Industrial Relations, held that matters pertaining to the relationship between those who work the land and agricultural enterprises fall under the exclusive jurisdiction of the Court of Agrarian Relations, as created by Republic Act No. 1267 . This jurisdiction encompasses the enforcement of laws governing capital-labor relations on agricultural lands. The subsequent enactment of Republic Act No. 2263 , which prohibited landholders from discouraging tenant unions, merely confirmed the agrarian court’s jurisdiction over such matters. Since the CIR improperly assumed jurisdiction, its decision was vacated and the case was ordered dismissed. The award of separation pay “for reasons of equity” was consequently nullified.