GR 80767; (April, 1991) (Digest)
G.R. No. 80767 ; April 22, 1991
BOY SCOUTS OF THE PHILIPPINES, petitioner, vs. NATIONAL LABOR RELATIONS COMMISSION, FORTUNATO ESGUERRA, ROBERTO MALABORBOR, ESTANISLAO MISA, VICENTE EVANGELISTA, and MARCELINO GARCIA, respondents.
FACTS
Private respondents were rank-and-file employees of petitioner Boy Scouts of the Philippines (BSP) stationed at its camp in Los Baños, Laguna. In October 1984, the BSP Secretary-General issued orders transferring them to a BSP land grant in Davao del Norte. The employees opposed the transfer, filed a complaint for illegal transfer with the Ministry of Labor, and refused to comply with the orders despite assurances of no salary diminution and a relocation allowance. Consequently, the BSP suspended and later terminated their services in February 1985 for insubordination. The employees amended their complaint to include illegal dismissal.
The Labor Arbiter initially dismissed the complaint, but the National Labor Relations Commission (NLRC) reversed this, ordering the employees’ reinstatement with backwages. The BSP filed this Petition for Certiorari to nullify the NLRC’s decision.
ISSUE
Whether the NLRC had jurisdiction over the complaint for illegal dismissal filed by the employees of the Boy Scouts of the Philippines.
RULING
The Supreme Court set aside the decisions of both the Labor Arbiter and the NLRC for lack of jurisdiction. The legal logic hinges on the constitutional definition of the Civil Service and the status of the BSP. Under Article IX(B), Section 2(1) of the 1987 Constitution , the Civil Service embraces all government agencies and instrumentalities, including government-owned or controlled corporations with original charters. The Court examined the BSP’s nature, noting it was created by Commonwealth Act No. 111 , as amended by Presidential Decree No. 460, which constitutes an original charter. Its governing structure, with the President of the Philippines as its President and key officials appointed by the President, and its performance of public functions, firmly established it as a government-controlled corporation.
Since the complaint was filed in 1984 when the analogous provision of the 1973 Constitution was in force, the precedent in National Housing Corporation vs. Juco applied. That ruling held that government-owned or controlled corporations with original charters fall under the Civil Service Commission’s jurisdiction, not the NLRC’s. Therefore, labor disputes involving their employees are outside the NLRC’s adjudicatory power. The Court emphasized that jurisdiction is conferred by law and can be raised motu proprio. As the BSP is a government-controlled corporation with an original charter, its employment relations are governed by civil service law, rendering the NLRC’s assumption of jurisdiction and subsequent decision void.