G.R. No. L-16803; June 29, 1964
KIM KEE, CHUA YU and CO., INC., petitioner, vs. COURT OF INDUSTRIAL RELATIONS and RIZALINO MANZANO, respondents.

FACTS

Rizalino Manzano filed a complaint on March 13, 1959, with the Court of Industrial Relations (CIR) against his former employer, Kim Kee, Chua Yu & Co., Inc. He alleged that from 1948 until his termination on January 31, 1959, he was employed as a labor inspector and was paid a monthly salary of P200. His claim sought solely the recovery of monetary compensation for 2,712 hours of allegedly unpaid overtime services rendered during his employment. The complaint did not include any request for reinstatement to his former position.
The petitioner corporation, in its answer, raised the special defense of lack of jurisdiction on the part of the CIR. It invoked the Supreme Court’s ruling in Chua Workers’ Union (NLU) vs. City Automotive Co., which delineated the jurisdictional boundaries of the industrial court. The trial judge of the CIR denied the plea to dismiss, and this ruling was upheld by the CIR en banc. The corporation thus filed the present petition for certiorari, seeking to annul the CIR’s orders for acting without jurisdiction.

ISSUE

Whether or not the Court of Industrial Relations had jurisdiction over Manzano’s complaint for the recovery of overtime pay, where the claim was purely monetary and did not include a prayer for reinstatement.

RULING

The Supreme Court granted the petition, reversing the CIR’s orders and dismissing the complaint for lack of jurisdiction. The legal logic is anchored on the established doctrine that the jurisdiction of the Court of Industrial Relations is limited and special. Following the precedent set in Chua Workers’ Union vs. City Automotive Co. and a line of subsequent decisions, the Court held that a claim filed by a former employee which is purely for the recovery of overtime compensation for work already rendered, and which does not seek reinstatement, constitutes a simple money claim.
Such a claim falls outside the ambit of the CIR’s jurisdiction. The CIR’s authority, under the governing laws, primarily extends to labor disputes involving unfair labor practices, cases involving the minimum wage law, and other matters affecting employer-employee relations where the ongoing relationship or conditions of employment are in issue. A severed employee’s purely monetary claim, absent a plea for reinstatement that would revive the employer-employee relationship, is an ordinary civil action cognizable by the regular courts. The Court distinguished the case from Monares vs. CNS Enterprises, which the CIR relied upon, by noting that in Monares, the ex-employee had asked for reinstatement, thereby bringing the case within the CIR’s purview. Since Manzano’s complaint contained no such request, the CIR had no authority to take cognizance of it. The dismissal was without prejudice to the filing of the action in the proper court of first instance.