G.R. No. L-14366; October 31, 1962
BOARD OF LIQUIDATORS and NATIONAL RESETTLEMENT AND REHABILITATION ADMINISTRATION, petitioners, vs. COURT OF INDUSTRIAL RELATIONS and EX-LASEDECO EMPLOYEES ASSOCIATION, respondents.

FACTS

The Ex-LASEDECO Employees’ Association filed a case before the Court of Industrial Relations (CIR) on December 3, 1956, seeking payment of the cash value of vacation and sick leaves for eighteen former employees of the defunct Land Settlement and Development Co. (LASEDECO), covering the period of the Japanese occupation. The action was premised on a prior 1953 CIR order in a separate case (Manlapit, et al. v. LASEDECO) which granted such benefits to other former LASEDECO employees. The petitioners in this case are the Board of Liquidators (BOL), tasked with liquidating LASEDECO’s assets, and the National Resettlement and Rehabilitation Administration (NARRA), which took over LASEDECO’s assets. The claimants were former government employees recalled to LASEDECO after liberation, received back pay certificates, and were laid off upon LASEDECO’s abolition.
The CIR, aligning with its 1953 ruling, ordered the petitioners to pay the claimed benefits. The petitioners moved for reconsideration, arguing the CIR lacked jurisdiction and erred in ordering payment for the occupation period. The CIR en banc denied the motion, prompting this certiorari petition. Petitioners specifically contended no employer-employee relationship existed between them and the claimants, thus depriving the CIR of jurisdiction.

ISSUE

Whether the Court of Industrial Relations had jurisdiction over the money claim for vacation and sick leave benefits filed by former employees against the liquidators and successor agency of their defunct former employer.

RULING

The Supreme Court ruled that the CIR had no jurisdiction over the case. The legal logic hinges on the established prerequisites for CIR jurisdiction over money claims. Following the doctrine solidified in Price Stabilization Corporation vs. CIR and clarified in Campos vs. Manila Railroad Co., the CIR’s jurisdiction is contingent upon: (a) the existence of an employer-employee relationship or a claim for reinstatement; and (b) the controversy relating to a case certified by the President involving national interest, an unfair labor practice charge, or a claim under the Eight-Hour Labor Law or the Minimum Wage Law. Absent these, the claim is a mere money claim falling under the jurisdiction of regular courts.
In this case, both prerequisites were absent. First, the claimants explicitly identified themselves as former employees of the defunct LASEDECO in their petition and did not seek reinstatement, especially since the corporation had been abolished. No employer-employee relationship existed with the BOL or NARRA. Second, the claim was a simple money claim for accrued leave benefits, not arising under the specific labor laws or circumstances granting CIR jurisdiction. The Court cited its prior ruling in a related case involving the same parties, which reached an identical conclusion on jurisdiction. Consequently, the CIR’s decision and resolution were set aside, without prejudice to the respondents filing their action in the proper regular court. The resolution of the jurisdictional issue rendered discussion of the other assigned error unnecessary.