G.R. No. 253149 . February 08, 2023.
JULIUS R. USON, PETITIONER, VS. PLDT EMPLOYEES CREDIT COOPERATIVE, NOEL P. SANTOS, JESUS L. SIY, MIGUEL B. DAWIS, AND SERGIO P. NAVARRA, RESPONDENTS.

FACTS

Petitioner Julius R. Uson was an active member of respondent PLDT Employees Credit Cooperative (PECCI), a cooperative registered with the Cooperative Development Authority (CDA). He held various positions, including committee secretary and director, before being appointed as Acting General Manager on October 10, 2013. His appointment as regular General Manager was formalized on May 19, 2014, effective May 22, 2014, and ratified by the PECCI Representative Assembly on March 28, 2015. On April 17, 2017, the PECCI Board of Directors passed a resolution declaring all appointive positions, including the General Manager, vacant. Consequently, Uson was required to turn over PECCI properties. Aggrieved, Uson filed a complaint for illegal dismissal before the Labor Arbiter (LA), claiming he was a regular employee illegally dismissed. PECCI argued that Uson was a cooperative officer and his dismissal constituted an intra-cooperative dispute under the jurisdiction of the CDA. The LA ruled in favor of Uson, finding him a regular employee illegally dismissed and awarding him backwages and separation pay. Both parties appealed to the National Labor Relations Commission (NLRC), which affirmed the LA’s jurisdiction and modified the monetary award. The Court of Appeals (CA) reversed the NLRC, holding that the labor tribunals lacked jurisdiction. The CA ruled that Uson, as General Manager, was a cooperative officer and his dismissal was an intra-cooperative dispute within the exclusive jurisdiction of the CDA, dismissing the complaint without prejudice to refiling in the proper forum.

ISSUE

Whether the present case is an intra-cooperative dispute within the jurisdiction of the Cooperative Development Authority (CDA) or an ordinary labor dispute within the jurisdiction of the labor tribunals.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals. The complaint for illegal dismissal filed by a cooperative officer is an intra-cooperative dispute, which is within the jurisdiction of the CDA. PECCI is a cooperative governed by the Philippine Cooperative Code of 2008 (RA 9520). Under Article 137 of the Cooperative Code and Section 4(t) of the CDA Charter (RA 11364), the CDA has original and exclusive jurisdiction over intra-cooperative disputes, which include controversies arising from the election or appointment of officers and directors. The General Manager is expressly listed as a cooperative officer under Article 42 of the Cooperative Code. Jurisdiction is determined by the allegations in the complaint and the law at the time of filing. Uson’s complaint, while framed as illegal dismissal, essentially involved the termination of his appointment as General Manager, a cooperative officer, by the Board of Directors. This is a matter inherently linked to the internal governance of the cooperative, constituting an intra-cooperative dispute. The principle of estoppel does not apply to questions of jurisdiction. Therefore, the labor tribunals had no jurisdiction over the case.