G.R. No. 82607 , July 12, 1990
Star Security and Detective Investigation Agency, petitioner, vs. The Secretary of Labor, Undersecretary of Labor, Regional Director David Kong, Jr. and Thelma Cuerda, respondents.

FACTS

Private respondent Thelma Cuerda filed a complaint on March 5, 1986, before the Regional Office of the then Ministry of Labor and Employment in Zamboanga City against petitioner Star Security and Detective Investigation Agency. The complaint alleged underpayment of minimum wage, emergency cost of living allowance, and non-payment of 13th month pay, regular holiday pay, rest day pay, and service incentive leave pay. Following an inspection and submission of payrolls for 1985, which petitioner stated could serve as a basis for claims from 1982 to 1985, the Regional Director issued an order on June 5, 1986, awarding Cuerda P14,280.00. This was later modified to P18,394.96.
Petitioner moved for reconsideration, contesting the Regional Director’s jurisdiction and the factual basis of the award. The Secretary of Labor upheld the Regional Director’s orders. Petitioner thus elevated the case to the Supreme Court via a petition for certiorari, arguing that the Regional Director lacked jurisdiction over the money claims.

ISSUE

Whether the Regional Director of the Department of Labor acted within his jurisdiction in taking cognizance of and adjudicating the money claims filed by private respondent Thelma Cuerda.

RULING

The Supreme Court ruled that the Regional Director had no jurisdiction. The Court applied the jurisdictional framework established under Republic Act No. 6715 , as interpreted in Brokenshire Memorial Hospital, Inc. vs. Minister of Labor and Briad Agro Development Corporation. For a Regional Director to validly exercise jurisdiction over money claims, three requisites must concur: (1) the claim is presented by an employee or househelper; (2) the claimant, no longer employed, does not seek reinstatement; and (3) the aggregate money claim does not exceed Five Thousand Pesos (P5,000.00).
In this case, the complaint indicated that Cuerda was relieved from employment due to an expired license and she did not seek reinstatement, thereby satisfying the first two requisites. However, her aggregate money claim far exceeded the P5,000.00 jurisdictional limit. Consequently, under the clear provisions of the law, the claim fell outside the Regional Director’s adjudicatory power. When the employment relationship no longer exists, reinstatement is not sought, and the claim exceeds P5,000.00, the case is exclusively cognizable by the Labor Arbiter. The Court emphasized that the Regional Director’s visitorial and enforcement powers under Article 128 of the Labor Code do not extend to adjudicating such contested claims exceeding the jurisdictional amount where evidentiary matters require formal hearing.
Thus, the assailed orders were reversed and set aside. The case was referred to the Labor Arbiter for proper proceedings if the private respondent so desired.