G.R. No. L-26933 October 18, 1977
CESAR JAYME AND CONCHITA JAYME, petitioners, vs. JUDGE SEVERIANO DE LEON, REYNOLD S. FAJARDO, FLAVIANO ALENTORIO, PEDRO ALLIEZA, ERNESTO CANDIDO, ROMEO CANDIDO, FRANCISCO CRISOSTOMO, JESUS CRISOSTOMO, JESUS CAONTOY, PROFIRIO DOLLAR, MELCHOR PALERMO, FLOR DELGADO, FERNANDO TAGACAY and COMMERCIAL & AGROINDUSTRIAL LABOR ORGANIZATION (CAILO), respondents.

FACTS

Petitioners Cesar and Conchita Jayme sought to annul the proceedings in CAR Case No. L-229 before the Court of Agrarian Relations (CAR) in Bacolod City. The case was an unfair labor practice complaint filed by agricultural workers against the Jaymes. The complaint was signed and filed by Reynold S. Fajardo, a CAR attorney-investigator, following a preliminary investigation. The petitioners moved to dismiss the case, arguing the CAR lacked jurisdiction because the complaint was signed by the investigator instead of the real parties in interest, and because the complaint included claims for moral and exemplary damages and differential pay, which they asserted were beyond the CAR’s jurisdiction. The respondent judge denied the motion to dismiss and a subsequent motion for reconsideration, prompting the Jaymes to file this petition for certiorari and prohibition.

ISSUE

The primary issue was whether the Court of Agrarian Relations acted without or in excess of its jurisdiction in denying the motion to dismiss and proceeding with the unfair labor practice case, considering the procedural objections raised by the petitioners regarding the complaint’s signing authority and the nature of the damages claimed.

RULING

The Supreme Court denied the petition. On the jurisdictional challenge, the Court clarified that the CAR undeniably possessed jurisdiction over unfair labor practice cases involving agricultural workers under Section 154 of the Agricultural Land Reform Code (R.A. 3844). The petitioners’ core objection was not to this substantive jurisdiction but to the procedural manner of enforcement—specifically, the investigator’s act of signing and filing the complaint. The Court held this procedure was sanctioned by law. Citing Section 17 of R.A. 1267 (the CAR Charter) and Section 155 of R.A. 3844, the Court ruled that the CAR was empowered to adopt its own procedural rules, and the investigator’s filing of the complaint after a preliminary inquiry was a valid exercise of this authority, ensuring speedy agrarian justice. Regarding claims for damages and differential pay, the Court affirmed the CAR’s jurisdiction to award these items as incidental relief necessary to effectuate its primary jurisdiction over the agrarian dispute, following established precedent. However, the Court took judicial notice of a supervening event: the enactment of the Labor Code (P.D. 442), which transferred jurisdiction over all labor disputes, including agricultural labor cases, to the National Labor Relations Commission and Labor Arbiters. Consequently, while upholding the CAR’s past actions, the Court ordered the records of CAR Case No. L-229 transferred to the proper Labor Arbiter in Bacolod City for further proceedings, dissolving the preliminary injunction.