GR 154295; (July, 2005) (Digest)
G.R. No. 154295. July 29, 2005
Metromedia Times Corporation and/or Robina Gokongwie-Pe, Petitioners, vs. Johnny Pastorin, Respondent.
FACTS
Johnny Pastorin, a Field Representative/Collector for Metromedia Times Corporation, obtained a personal loan from a company dealer, Gloria de Manuel. After Pastorin defaulted, de Manuel complained to Metromedia. The company suspended Pastorin for four days for violating company policy and subsequently transferred him to a different department. Pastorin refused the transfer and stopped reporting for work. He then filed a complaint for constructive dismissal with the Labor Arbiter.
The Labor Arbiter ruled in favor of Pastorin, ordering his reinstatement with backwages. Metromedia appealed to the NLRC, raising for the first time the argument that the Labor Arbiter lacked jurisdiction. Metromedia contended that the case, involving the propriety of a union member’s reassignment, was a grievance matter under the Collective Bargaining Agreement and thus fell under the exclusive jurisdiction of a voluntary arbitrator. The NLRC reversed the Labor Arbiter and dismissed the complaint for lack of jurisdiction.
ISSUE
Whether a party who actively participated in the proceedings before the Labor Arbiter is estopped from raising the issue of lack of jurisdiction over the subject matter for the first time on appeal before the NLRC.
RULING
No. The Supreme Court ruled that lack of jurisdiction over the subject matter can be raised at any stage of the proceedings, even on appeal, and is not subject to waiver or estoppel. The Court distinguished between jurisdiction over the subject matter and jurisdiction over the person. While a party may be estopped from questioning jurisdiction over their person due to voluntary submission, the same principle does not apply to subject matter jurisdiction.
The Court clarified that the doctrine of estoppel by laches, which bars a belated jurisdictional challenge, applies only in exceptional circumstances, such as when a party has actively participated in the proceedings over an unreasonable length of time. Here, Metromedia raised the jurisdictional issue at its first opportunity in the appellate stage before the NLRC. There was no inordinate delay or conduct indicative of estoppel. Since the issue involved the interpretation and implementation of the CBA regarding a union member’s reassignment, it was indeed a grievance falling under the exclusive jurisdiction of the voluntary arbitrator, not the Labor Arbiter. Consequently, the NLRC correctly dismissed the complaint for lack of jurisdiction. The Court reversed the Court of Appeals and reinstated the NLRC decision.