GR 85840; (June, 1991) (Digest)
G.R. No. 85840 ; June 5, 1991
SERVANDO’S INCORPORATED, petitioner, vs. THE SECRETARY OF LABOR AND EMPLOYMENT AND THE REGIONAL DIRECTOR REGION VI, DEPARTMENT OF LABOR AND EMPLOYMENT, respondents.
FACTS
This case originated from a motion for reconsideration filed by the Secretary of Labor and the Regional Director. They sought to overturn the Court’s April 26, 1990 decision, which had ordered the referral of a labor case involving fifty-four (54) employees of Servando’s Incorporated to the appropriate Labor Arbiter. The Court’s prior ruling held that since the aggregate claims of each employee exceeded Five Thousand Pesos (P5,000.00), the case fell within the exclusive jurisdiction of the Labor Arbiter, not the Regional Director.
The respondents argued for a broader interpretation of the Secretary of Labor’s visitorial and enforcement powers under Article 128(b) of the Labor Code. They contended that this power is separate from the Regional Director’s adjudicatory power over simple money claims under Article 129 and should not be limited by Article 217, which grants Labor Arbiters exclusive jurisdiction over money claims exceeding P5,000.00. They essentially posited that the Secretary’s power to enforce labor standards compliance could encompass the adjudication of large monetary claims discovered during inspections.
ISSUE
Whether the Secretary of Labor, in the exercise of visitorial and enforcement powers under Article 128(b) of the Labor Code, has jurisdiction to hear and decide employees’ money claims where the aggregate amount for each employee exceeds P5,000.00.
RULING
No. The Supreme Court, en banc, denied the motion for reconsideration and reaffirmed that the Labor Arbiter holds exclusive jurisdiction over money claims exceeding P5,000.00 per employee. The Court harmonized Articles 128(b), 129, and 217 of the Labor Code. While Article 128(b) grants the Secretary of Labor plenary visitorial powers to inspect for violations and order compliance with labor standards, the power to adjudicate the resulting monetary claims is distinctly allocated by Articles 129 and 217.
Article 129 explicitly limits the Regional Director’s jurisdiction to claims where the aggregate for each employee does not exceed P5,000.00. Correspondingly, Article 217(a)(6) grants Labor Arbiters original and exclusive jurisdiction over all other claims arising from employer-employee relations involving amounts exceeding P5,000.00. To allow the Secretary to decide claims over P5,000.00 under visitorial powers would render these specific jurisdictional provisions meaningless and sanction a situation where all claims, regardless of amount, could bypass the Labor Arbiter, contrary to legislative intent. Therefore, when an inspection reveals claims exceeding the jurisdictional amount, the Secretary must refer the matter to the Labor Arbiter for adjudication.