GR 106722; (October, 1996) (Digest)
G.R. No. 106722 October 4, 1996
JOSEMARIA G. ESTRADA, petitioner, vs. THE HONORABLE NATIONAL LABOR RELATIONS COMMISSION and PHILIPPINE AIRLINES, INC., respondents.
FACTS
Petitioner Josemaria Estrada was the Senior Vice-President for Marketing of Philippine Airlines, Inc. (PAL). In 1990, he was implicated in a major corporate anomaly, preventively suspended, and subsequently administratively charged. Following an investigation, PAL’s Board of Directors passed a resolution declaring him resigned from service effective immediately for loss of confidence and acts inimical to the company. Estrada filed a complaint for illegal dismissal with the Labor Arbiter, praying for reinstatement, backwages, damages, and other benefits.
The Labor Arbiter ruled in Estrada’s favor, ordering his reinstatement and the payment of monetary claims. On appeal, the National Labor Relations Commission (NLRC) reversed the decision and dismissed the complaint. The NLRC held that it lacked jurisdiction, ruling that the case, involving the dismissal of a corporate officer by the Board of Directors, fell within the original and exclusive jurisdiction of the Securities and Exchange Commission (SEC) under Presidential Decree No. 902-A.
ISSUE
The primary issue is whether the NLRC has jurisdiction over Estrada’s complaint for illegal termination, or if jurisdiction properly lies with the SEC.
RULING
The Supreme Court dismissed the petition, affirming the NLRC’s ruling that it lacked jurisdiction. The Court applied its prior decisions in the consolidated cases of Lozon v. NLRC and Espino v. NLRC, where other dismissed PAL executive vice-presidents involved in the same anomaly raised identical issues. The Court held that the dismissal of a corporate officer by the Board of Directors is always a corporate act, making the controversy intra-corporate in nature. Jurisdiction over such controversies is vested by law in the SEC, not the Labor Arbiter.
The Court explained that the nature of the controversy is not altered by the inclusion of claims for backwages and damages. These monetary claims are deemed part of the perquisites of the corporate office and are intimately linked to Estrada’s relations with the corporation, thus falling within the SEC’s specialized competence. The Court also found that PAL was not estopped from questioning jurisdiction, as it raised the issue from the arbitration level, and jurisdiction over the subject matter can be questioned at any time.