GR 116236; (October, 1996) (Digest)
G.R. No. 116236 October 2, 1996
Victorias Milling Co., Inc., petitioner, vs. National Labor Relations Commission and National Federation of Sugar Workers-Food and General Trades (NFSW-FGT), respondents.
FACTS
The National Federation of Sugar Workers-Food and General Trades (NFSW-FGT) filed a complaint before the NLRC against Victorias Milling Co., Inc., a sugar central, and various hacienda planters. The suit sought to recover the alleged share of farm workers in increased sugar deliveries from 1952 to 1984, as provided under Republic Act No. 809 (The Sugar Act of 1952). Victorias Milling moved to dismiss the complaint for lack of jurisdiction, arguing that no employer-employee relationship existed between the sugar central and the farm workers represented by the union.
The labor arbiter denied the motion to dismiss, a decision affirmed by the NLRC. The Commission held that it had jurisdiction over the money claim. Victorias Milling elevated the case to the Supreme Court via a petition for certiorari, reiterating its sole contention that the labor tribunals lacked jurisdiction due to the absence of an employer-employee relationship.
ISSUE
Whether or not the National Labor Relations Commission has jurisdiction over a money claim filed by sugar farm workers against a sugar central with whom no employer-employee relationship exists.
RULING
The Supreme Court granted the petition and ordered the dismissal of the case against Victorias Milling. The Court ruled that the jurisdiction of labor arbiters and the NLRC under Article 217 of the Labor Code is limited to cases arising from or connected with an employer-employee relationship. Citing the precedent in Federation of Free Farmers v. Court of Appeals, the Court emphasized that a sugar central has no privity with the plantation workers; its dealings are exclusively with the planter. Republic Act No. 809, which governs the sharing of sugar proceeds, does not create any employer-employee link between the central and the farm workers.
The legal logic is clear: jurisdiction is conferred by law. Since the claim against the central is not rooted in an employer-employee relation, it falls outside the specialized and limited jurisdiction of the labor tribunals. The workers’ claim, if it exists, is against their direct employers—the planters—and must be pursued against them in the proper forum. The central is not an indispensable party to such a suit, as no judgment can obligate it to pay the workers’ share directly.