GR 38893; (August, 1977) (Digest)
G.R. No. L-38893 August 3, 1977
RUBY INDUSTRIAL CORPORATION, petitioner, vs. THE COURT OF FIRST INSTANCE OF MANILA, BRANCH XXVII, FELIX FLORES, in his capacity as Compulsory Arbitrator of the National Labor Relations Commission and LEONILA RAMIREZ, respondents.
FACTS
Leonila Ramirez, a worker, filed a complaint against her employer, Ruby Industrial Corporation, before the National Labor Relations Commission (NLRC). Her claims included underpayment, overtime pay, and separation pay covering the period from November 1969 to October 1972. The petitioner corporation moved to dismiss the complaint, asserting that the NLRC lacked jurisdiction over the subject matter. The NLRC denied this motion and proceeded with the case.
Unsatisfied with the NLRC’s order, Ruby Industrial Corporation elevated the matter to the Court of First Instance of Manila via a petition for certiorari, mandamus, and prohibition, reiterating its jurisdictional challenge. The lower court dismissed the corporation’s petition and lifted its restraining order. The corporation then filed the present petition for certiorari before the Supreme Court, insisting that the NLRC had no authority to adjudicate the claims for separation pay, wage differentials, and overtime pay.
ISSUE
Whether or not the National Labor Relations Commission had jurisdiction to arbitrate and adjudicate the monetary claims of private respondent Leonila Ramirez against the petitioner corporation.
RULING
The Supreme Court ruled affirmatively, holding that the NLRC possessed jurisdiction over the complaint. The legal logic centers on the jurisdictional scope of the NLRC as defined by Presidential Decree No. 21 and its implementing rules. The Court emphasized that under the pertinent rules promulgated by the Commission, it had authority over all matters involving employer-employee relations, including disputes and grievances, irrespective of the date the cause of action accrued. The only explicit exception was for cases already pending in any court on or before September 21, 1972.
Applying this rule to the facts, the Court found that Ramirez’s complaint was instituted on July 31, 1973, which was well after the critical date of September 21, 1972. Consequently, her claim was not among the excluded cases and fell squarely within the original and exclusive jurisdiction of the NLRC as mandated by law. The petitioner’s argument that the NLRC lacked jurisdiction was therefore without merit. The Court dismissed the petition, affirming the decisions of the lower court and the NLRC, and noted the unfortunate delay caused by the corporation’s unwarranted jurisdictional challenge.