GR 56428; (February, 1992) (Digest)
G.R. No. L-56428 February 18, 1992
SOUTHERN FOOD SALES CORPORATION AND ROBERT JAMES SIAO, petitioners, vs. HON. BERNARDO LL. SALAS, PRESIDING JUDGE OF BRANCH VIII, COURT OF FIRST INSTANCE OF CEBU AND RAUL G. LAURENTE, respondents.
FACTS
Private respondent Raul G. Laurente, a former sales supervisor of petitioner Southern Food Sales Corporation, was terminated for alleged gross neglect and dishonesty. On August 27, 1979, he filed a civil case for damages against the corporation and its manager, Robert James Siao, in the Court of First Instance of Cebu. Subsequently, on November 20, 1979, he filed a separate complaint for illegal dismissal with the Ministry of Labor. The Labor Arbiter later ruled on February 5, 1980, that the dismissal was for a just cause, a decision which Laurente appealed to the NLRC.
In the interim, petitioners filed a motion to dismiss the civil case, arguing that jurisdiction over claims for damages arising from employer-employee relations was vested in the Labor Arbiters. The respondent judge issued an order dated February 28, 1980, deferring resolution of the motion to dismiss until after trial, and later denied the motion for reconsideration on November 6, 1980. Petitioners thus filed this certiorari petition, contending the judge committed grave abuse of discretion.
ISSUE
Whether the respondent judge committed grave abuse of discretion in deferring the resolution of the motion to dismiss which questioned the court’s jurisdiction over the claim for damages.
RULING
The Supreme Court dismissed the petition, finding no grave abuse of discretion. The legal logic hinges on the applicable law at the time the civil action was instituted in 1979. The Court clarified that jurisdiction is determined by the law in force at the time of the filing of the complaint. At that time, Presidential Decree No. 1367 governed, whose Article 217(a)(3) explicitly stated that Labor Arbiters “shall not entertain claims for moral or other forms of damages.” Consequently, the regular courts, like the CFI, retained jurisdiction over such damage claims.
The Court rejected the petitioners’ argument based on the subsequent amendments by Republic Act No. 6715 , which granted Labor Arbiters jurisdiction over damage claims. It applied the settled rule that a statute changing jurisdiction is not applied retroactively to pending actions unless expressly provided. Since RA 6715 contained no such express retroactive provision, it could not divest the CFI of the jurisdiction it had already rightfully acquired in 1979. Therefore, the respondent judge was correct in proceeding with the case, and his order deferring the motion to dismiss was a proper exercise of jurisdiction, not an abuse thereof.