G.R. No. L-18962 December 23, 1964
SANTIAGO MERCADO, plaintiff-appellant, vs. ELIZALDE AND COMPANY, INC., defendant-appellee.

FACTS

Santiago Mercado was employed as a watchman by Elizalde and Company, Inc. in Cebu City in April 1947, with a monthly salary of P80.00. After the enactment of Republic Act No. 602 (Minimum Wage Law), Mercado requested his employer to adjust his salary in compliance with the new law and to pay him overtime compensation for services rendered beyond eight hours as required by Commonwealth Act No. 444 (Eight-Hour Labor Law). The company ignored his request. Mercado then filed a complaint with the Wage Administration Service. Upon being notified, the company’s branch manager threatened Mercado with termination if he did not withdraw the complaint. Mercado refused to withdraw unless his salary was adjusted, leading to his dismissal effective September 30, 1956. Mercado filed an action in the Court of First Instance of Cebu seeking reinstatement with back wages under the Minimum Wage Law and payment of overtime pay under the Eight-Hour Labor Law. Meanwhile, the Wage Administration Service decided in Mercado’s favor, awarding him P9,508.50 for salary differential and overtime pay. When this decision became final, Mercado filed an enforcement action in the Court of First Instance of Cebu, but it was dismissed for lack of jurisdiction. The Supreme Court later dismissed a certiorari petition on the same ground, without prejudice to other appropriate actions. The Court of First Instance of Cebu, in the present case, also declared itself without jurisdiction and dismissed Mercado’s complaint, prompting this appeal.

ISSUE

Whether the Court of First Instance of Cebu has jurisdiction over Mercado’s action for reinstatement with back wages and overtime pay arising from alleged violations of the Minimum Wage Law and the Eight-Hour Labor Law.

RULING

No. The Supreme Court affirmed the dismissal of the case by the Court of First Instance of Cebu for lack of jurisdiction. The Court held that the case falls under the jurisdiction of the Court of Industrial Relations because it involves: (1) an employer-employee relationship where the claimant seeks reinstatement; and (2) a controversy arising under both the Eight-Hour Labor Law and the Minimum Wage Law. Citing Campos, et al. v. Manila Railroad Company, et al. (L-17905, May 25, 1962), the Supreme Court reiterated that for the Court of Industrial Relations to acquire jurisdiction under Republic Act No. 875 , the controversy must involve either a case certified by the President as one of national interest, an unfair labor practice charge, or a claim arising under the Eight-Hour Labor Law or the Minimum Wage Law, coupled with an employer-employee relationship or a claim for reinstatement. Absent these circumstances, the claim would be a mere money claim within the jurisdiction of regular courts. Since Mercado’s action met the criteria for the Court of Industrial Relations’ jurisdiction, the Court of First Instance correctly dismissed it. The decision appealed from was affirmed, without costs.