G.R. No. 172642 ; June 13, 2012
ESTATE OF NELSON R. DULAY, represented by his wife MERRIDY JANE P. DULAY, Petitioner, vs. ABOITIZ JEBSEN MARITIME, INC. and GENERAL CHARTERERS, INC., Respondents.

FACTS

Nelson R. Dulay was employed by respondent General Charterers Inc. as a seafarer. He completed his contract on July 19, 2000, and died on August 13, 2000, due to acute renal failure. His widow, Merridy Jane Dulay, filed a complaint for death benefits with the NLRC, claiming US$90,000 under the Collective Bargaining Agreement (CBA) between the Associated Marine Officers and Seamen’s Union of the Philippines and the employer. The respondents contested NLRC jurisdiction, arguing the death occurred after the contract term and was not work-related, and that liability was limited to a smaller amount under a different CBA provision, which had been settled by a P20,000 payment received by the seafarer’s brother.
The Labor Arbiter and the NLRC ruled in favor of the widow, awarding the benefits. The respondents filed a certiorari petition with the Court of Appeals, which granted the petition. The CA held that the core issue involved the interpretation of the CBA provisions—specifically, which article applied to the claim—and thus, jurisdiction properly belonged to the voluntary arbitrator, not the Labor Arbiter. The petitioner’s motion for reconsideration was denied.

ISSUE

Whether the Court of Appeals erred in ruling that the Labor Arbiter had no jurisdiction over the complaint for death benefits under the CBA.

RULING

The Supreme Court denied the petition and affirmed the CA decision. The Court held that jurisdiction lies with the voluntary arbitrator, not the Labor Arbiter. While Republic Act No. 8042 (Migrant Workers Act) grants Labor Arbiters original and exclusive jurisdiction over money claims of overseas workers, this general grant is not absolute. Article 217(c) of the Labor Code provides a specific exception: cases arising from the interpretation or implementation of collective bargaining agreements shall be referred to the grievance machinery and voluntary arbitration.
The Court applied the rule of statutory construction that a special law governs a general law. Here, Article 217(c) of the Labor Code is the specific provision governing disputes involving CBA interpretation. The petitioner’s claim fundamentally hinged on determining whether Article 20(A)1 or Article 20(A)2 of the CBA applied—a question of contractual interpretation. Therefore, the general jurisdictional grant in R.A. 8042 must yield to the specific procedural mandate of Article 217(c). This ruling aligns with the constitutional and statutory policy promoting voluntary arbitration as the primary mode for settling disputes involving CBA interpretation to foster industrial peace.