GR 95559; (November, 1993) (Digest)
G.R. No. 95559 November 9, 1993
ALBAY I ELECTRIC COOPERATIVE, INC. (ALECO I), petitioner, vs. RICARDO S. MARTINEZ, Sr., ARNOLD B. BONAGUA and CONRADO S. BUBAN, respondents.
FACTS
On August 15, 1988, private respondents Conrado Buban and Arnaldo Bonagua were designated as acting manager and supervisor, respectively, of Albay I Electric Cooperative, Inc. (ALECO I) by its Acting General Manager, Israel Garcia. These appointments were made after Garcia’s own appointment was recalled by the National Electrification Administration (NEA). On August 27, 1988, ALECO I’s Board of Directors declared these “midnight appointments” null and void. A subsequent NEA memorandum also considered the appointments defective. On August 15, 1989, private respondents filed a complaint with the Regional Director of the Department of Labor and Employment (DOLE) for recovery of salary differentials corresponding to their new positions, arguing they held these positions for over a year and should be considered permanent. Petitioner moved to dismiss for lack of jurisdiction. Nonetheless, the Regional Director issued orders on September 11, 1989 and September 3, 1990, directing petitioner to pay the claimed amounts (which exceeded P5,000.00 for each respondent) and issued a writ of execution. Petitioner filed this special civil action for certiorari, arguing the Regional Director acted without jurisdiction as the money claims exceeded P5,000.00.
ISSUE
Whether or not the Regional Director of the DOLE had jurisdiction to hear and decide the private respondents’ complaint for recovery of salary differentials and 13th month pay, where the amount claimed by each employee exceeded P5,000.00.
RULING
No. The Supreme Court ruled that the Regional Director acted without jurisdiction. Under Articles 129 and 217 of the Labor Code, as amended by R.A. 6715, the Labor Arbiter has exclusive original jurisdiction over all claims arising from employer-employee relations where the aggregate money claim of each employee exceeds P5,000.00. The Court clarified that the Regional Director’s adjudicative power under Article 129 is limited to claims not exceeding P5,000.00 per employee, provided the claimant does not seek reinstatement. The Court also held that the visitorial power of the Regional Director under Article 128 of the Labor Code cannot be invoked to adjudicate claims exceeding P5,000.00, as this would render the jurisdictional limits in Articles 129 and 217 meaningless. Since the claims of private respondents individually exceeded P5,000.00, jurisdiction properly belonged to the Labor Arbiter. Consequently, the assailed Orders and the writ of execution issued by the Regional Director were declared null and void. The case was referred to the proper Labor Arbiter for appropriate determination.