GR 113212; (December, 1995) (Digest)
G.R. No. 113212 . December 29, 1995.
THE DEPARTMENT OF HEALTH (DR. JOSE N. RODRIGUEZ MEMORIAL HOSPITAL) and CESAR J. VIARDO, M.D., in his capacity as Director of the Dr. Jose N. Rodriguez Memorial Hospital, petitioners, vs. NATIONAL LABOR RELATIONS COMMISSION, LABOR ARBITER CORNELIO L. LINSANGAN and CEFERINO R. LAUR, respondents.
FACTS
Private respondent Ceferino R. Laur, a former leprosy patient, was employed in 1975 as a patient-assistant and member of the Patient-Assistant Police Force at the Dr. Jose N. Rodriguez Memorial Hospital (DJRMH), a government hospital. His salary was charged to the hospital’s maintenance and operating expenses. Following a mauling incident in July 1990 involving a civilian, Laur was dismissed by Hospital Director Dr. Cesar J. Viardo. Consequently, Laur filed a complaint for illegal dismissal with monetary claims before the National Labor Relations Commission (NLRC). Labor Arbiter Cornelio Linsangan ruled in Laur’s favor, ordering his reinstatement with backwages and the payment of various monetary awards. The NLRC dismissed the hospital’s appeal, prompting the petitioners to file this certiorari petition.
ISSUE
Whether the NLRC or the Civil Service Commission (CSC) has jurisdiction over the illegal dismissal case filed by Ceferino R. Laur, an employee of a government hospital.
RULING
The Supreme Court ruled that the CSC, not the NLRC, has jurisdiction. The legal logic is anchored on the fundamental principle that jurisdiction over government employees is determined by the nature of the employing entity. DJRMH is a government hospital operating as an agency under the Department of Health, and its personnel, including Laur, fall under the ambit of the civil service. The Court emphasized that Article 276 of the Labor Code explicitly provides that the terms and conditions of employment of government employees are governed by the Civil Service Law, rules, and regulations. Consequently, disputes involving the discipline and removal of such employees are within the exclusive original jurisdiction of the CSC. The Labor Arbiter and the NLRC therefore acted without jurisdiction. The Court further held that jurisdiction is conferred by law and cannot be vested by the parties’ agreement or estopped by their participation in the proceedings. The assailed NLRC Resolution and Labor Arbiter’s Decision were declared null and void and accordingly set aside.