G.R. No. 124915; February 18, 2008
RIZAL SECURITY & PROTECTIVE SERVICES INC., and/or RUFINO S. ANTONIO, JR., petitioners, vs. HON. DIRECTOR ALEX E. MARAAN, Regional Sheriff of DOLE, Cordillera Administrative Region, and RICO GOMEZ, et al., respondents.

FACTS

Private respondents, former security guards of petitioner Rizal Security, filed a complaint with the DOLE-CAR for various labor standard violations, including underpayment of wages and non-payment of overtime and holiday pay. Following an inspection that confirmed violations, the DOLE-CAR scheduled hearings. During the proceedings, the guards submitted resignation letters effective September 1, 1995, and the client, Rainbow End Village, terminated its contract with Rizal Security on the same date. Petitioners then filed a Manifestation and Motion arguing that the DOLE-CAR lost jurisdiction because the employer-employee relationship had ceased due to the resignations.
Public respondent DOLE-CAR Regional Director Alex E. Maraan denied the motion and issued an Order dated January 24, 1996, directing petitioners to pay monetary deficiencies. Petitioners’ counsel claimed he never officially received a copy of this Order. Subsequently, on May 8, 1996, counsel received a Writ of Execution dated March 12, 1996, enforcing the January 24 Order, which stated it had become final and executory.

ISSUE

Whether the DOLE Regional Director retained jurisdiction to issue the final order and writ of execution despite the termination of the employer-employee relationship during the proceedings.

RULING

Yes, the DOLE Regional Director retained jurisdiction. The Court ruled that the existence of an employer-employee relationship is only a prerequisite for the initiation of a complaint under Article 128(b) of the Labor Code, as amended by Republic Act No. 7730. This provision grants the Secretary of Labor or his authorized representatives, like the Regional Director, visitorial and enforcement powers to adjudicate money claims arising from labor standards violations. Once a complaint is validly filed while such relationship exists, jurisdiction is acquired and is not lost by subsequent events, such as the resignation of the employees or termination of the service contract.
The legal logic is that the labor standards claims are rooted in violations that occurred during the period of employment. The cessation of the relationship does not extinguish the employer’s liability for obligations accrued prior to termination. The Court emphasized that the Regional Director’s authority under Article 128(b) is premised on the filing of the complaint, not on the continuous existence of the employment tie throughout the adjudication. Therefore, the DOLE-CAR correctly proceeded to resolve the money claims and issue the writ of execution. The petition for certiorari was dismissed for lack of merit, affirming the Regional Director’s order.