GR 89362; (November, 1991) (Digest)
G.R. No. 89362 November 29, 1991
JOSE BARITUA, petitioner, vs. SECRETARY OF THE DEPARTMENT OF LABOR AND EMPLOYMENT, DEOGRACIAS IMPERIAL, RODOLFO ABUEDO, BENJAMIN MARANO, VIRGILIO AGUILA, MIGUEL RAMOS, and MANUEL MORENO, respondents.
FACTS
Private respondents, employees of petitioner Jose Baritua, filed a complaint for unpaid night shift differential, service incentive leave pay, premium pay for rest day, and overtime pay. After failed conciliation, the case was elevated to the Department of Labor and Employment (DOLE). The Regional Director assumed jurisdiction, ordered a conference, and required position papers. Petitioner contested the Regional Director’s jurisdiction, arguing the Labor Arbiter was the proper forum, and denied the monetary claims on various grounds including prescription and payment. The Regional Director issued an order directing petitioner to pay the employees a total of P206,136.60.
Petitioner appealed to the Secretary of Labor, reiterating the jurisdictional challenge. The Secretary dismissed the appeal and affirmed the Regional Director’s order, prompting this petition for certiorari.
ISSUE
Whether the Regional Director had jurisdiction to adjudicate the private respondents’ monetary claims.
RULING
No. The Supreme Court set aside the Secretary of Labor’s order and referred the case to the Labor Arbiter. The legal logic hinges on the applicable law governing the jurisdiction of Regional Directors over money claims at the time of the complaint’s filing in 1988. While Executive Order No. 111 had expanded such jurisdiction, the subsequent enactment of Republic Act No. 6715 (the Herrera-Veloso Law), which took effect on March 21, 1989, was determinative. This law, amending Articles 129 and 217 of the Labor Code, explicitly conferred adjudicatory power on Regional Directors only under three conditions: (1) the claimant is an employee or househelper; (2) the claimant does not seek reinstatement; and (3) the aggregate money claim per employee does not exceed Five Thousand Pesos (P5,000.00).
The Court found that the private respondents’ claims, each exceeding P34,000.00, clearly surpassed the P5,000.00 jurisdictional limit set by R.A. 6715. Consequently, the Regional Director lacked jurisdiction. Furthermore, the Court noted that the contentious factual and legal issues raised by both parties were better suited for the more formal and extensive proceedings available before the Labor Arbiter. Therefore, the case was properly remanded for adjudication by the Labor Arbiter.