GR L 15485; (May, 1960) (Digest)
G.R. No. L-15485; May 23, 1960
BOARD OF LIQUIDATORS and NATIONAL RESETTLEMENT AND REHABILITATION ADMINISTRATION, petitioners, vs. COURT OF INDUSTRIAL RELATIONS and EX-LASEDECO EMPLOYEES ASSOCIATION, respondents.
FACTS
The Ex-Lasedeco Employees Association, representing 211 former employees of the defunct Land Settlement and Development Corporation (LASEDECO), filed a petition in the Court of Industrial Relations (CIR) against the Board of Liquidators (BOL) and the National Resettlement and Rehabilitation Administration (NARRA). The claims included alleged underpayment of salaries and wages from November 1953 to June 18, 1954, separation pay, gratuity under Republic Act 1160, and sick and vacation leave pay, plus damages. The petitioners moved to dismiss the case on the ground, among others, of lack of jurisdiction of the CIR. The CIR denied the motion to dismiss, deferred the resolution on jurisdiction until after the hearing on the merits, and later rendered a judgment declaring it had jurisdiction and ordering the BOL to compute and the NARRA to pay the claims. The petitioners’ motion for reconsideration was denied, prompting this petition for review on certiorari.
ISSUE
Whether the Court of Industrial Relations has jurisdiction to hear and adjudicate the monetary claims of the respondent Ex-Lasedeco Employees Association.
RULING
The Supreme Court ruled that the Court of Industrial Relations does not have jurisdiction over the case. The Court set aside the questioned decision and resolution of the CIR.
The Supreme Court held that the jurisdiction of the Court of Industrial Relations over money claims arising from employment is contingent upon the existence of an employer-employee relationship or when reinstatement is sought due to its wrongful severance. In this case, the claimants were former employees of the defunct LASEDECO, laid off in November 1953, and they did not seek reinstatement. Their claims—for back salaries, separation pay, gratuity, and leave pay—were purely civil or monetary obligations arising from a terminated employment relationship. Consequently, the action for their collection falls within the jurisdiction of the regular courts (Courts of First Instance) and not the Court of Industrial Relations. The Court cited the principle established in Price Stabilization Corporation vs. Court of Industrial Relations, clarifying that after the termination of the employer-employee relationship with no reinstatement sought, such claims become mere money claims under the jurisdiction of regular courts. Given this conclusion on jurisdiction, the Court deemed it unnecessary to address the other assigned errors regarding the liability of NARRA and the accrual of the cause of action.