GR L 1232; (January, 1948) (Digest)
G.R. No. L-1232; January 12, 1948
METROPOLITAN TRANSPORTATION SERVICE (METRAN), Petitioner, vs. JOSE MA. PAREDES, VICENTE DE LA CRUZ and ARSENIO C. ROLDAN, Judges of Court of Industrial Relations, and THE NATIONAL LABOR UNION, Respondents.
FACTS
The National Labor Union filed a petition before the Court of Industrial Relations (CIR) against the Metropolitan Transportation Service (METRAN), a semi-governmental transportation entity created by Executive Order No. 59 and operating under the Department of Public Works and Communications. METRAN moved to dismiss the case on the ground that, as an entity belonging to the Republic of the Philippines, it could not be sued without its consent. The CIR denied the motion to dismiss and a subsequent motion for reconsideration. METRAN appealed the denial to the Supreme Court.
ISSUE
Whether the Court of Industrial Relations had jurisdiction to take cognizance of the case against METRAN, considering it is a non-corporate government agency.
RULING
No. The Supreme Court granted the petition and declared the proceedings before the CIR null and void. The Court held that METRAN is not a juridical person under the law; it is a mere office or agency of the Government. A suit against it is, in effect, a suit against the Government itself. The Government cannot be sued without its consent, and no such consent was shown. Furthermore, under the Rules of Court, only natural or juridical persons may be parties in a civil action. Since METRAN is neither, it could not be sued. Therefore, the CIR lacked jurisdiction over the case. (A dissenting opinion argued that when the government operates a public utility, it should be treated like a private entity and subject to the CIR’s jurisdiction to ensure its workers are not deprived of the protection of labor laws.)
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