G.R. No. 96617 October 14, 1992
LOLITA B. JAVIER, in her own behalf and as guardian of her six minor children, petitioner, vs. HONORABLE COURT OF APPEALS, JEBSENS MARITIME, INC., and FIDEL E. DIÑOSO, respondents.

FACTS

Normito Javier, husband of petitioner Lolita Javier, was employed by private respondent Jebsens Maritime, Inc. as a boatswain on the M/V “General Campos.” On September 23, 1987, while preparing a pilot ladder on orders of the shipmaster, private respondent Fidel Diñoso, a sudden swell caused Javier to fall into the sea off Corona, Spain. A search failed to find him. His body was later discovered by fishermen and was buried in Spain on October 3, 1987, without the knowledge or consent of his family. After learning of his death, petitioner approached the company, which promised to give death benefits. Upon the company’s failure to pay, petitioner, for herself and her six minor children, filed a complaint for a sum of money with the Regional Trial Court (RTC) of Makati on May 30, 1988. During trial, private respondents’ new counsel filed a Motion to Dismiss on January 24, 1989, on the ground of lack of jurisdiction, arguing the case fell under the original and exclusive jurisdiction of the Philippine Overseas Employment Administration (POEA). The RTC denied the motion. Private respondents then filed a Petition for Certiorari and Prohibition with the Court of Appeals, which granted the petition, annulled the RTC proceedings, and ordered the dismissal of the case for lack of jurisdiction. Petitioner’s Motion for Reconsideration was denied.

ISSUE

Whether the Regional Trial Court has jurisdiction over petitioner’s claim for death benefits arising from the overseas employment of her deceased husband, or whether such claim falls under the original and exclusive jurisdiction of the Philippine Overseas Employment Administration (POEA).

RULING

The Supreme Court DENIED the petition for certiorari, upholding the decision of the Court of Appeals. The Court ruled that the POEA has original and exclusive jurisdiction over the claim. Section 3(d) of Executive Order No. 247 provides that the POEA shall exercise original and exclusive jurisdiction over all claims arising out of an employer-employee relationship involving Filipino workers for overseas employment. Since the claim is indisputably rooted in an employer-employee relationship, jurisdiction is vested in the POEA. The Court rejected the argument that the regular courts could take cognizance of the civil aspect, as this would lead to a multiplicity of suits. The Court also held that the doctrine of estoppel could not be invoked against private respondents for having participated in the RTC proceedings, as the issue of jurisdiction may be raised at any time and any stage of the action, and a decision rendered by a tribunal without jurisdiction is null and void.