G.R. No. L-14837, L-15483, L-13940, L-15015. June 30, 1961.
JOSE COROMINAS, JR. and COROMINAS & CO., INC., petitioners, vs. LABOR STANDARDS COMMISSION, ET AL., respondents. MANILA CENTRAL UNIVERSITY, plaintiff-appellee, vs. JOSE CALUPITAN, ET AL., defendants-appellants. WONG CHUN alias HA HING, plaintiff-appellant, vs. DIEGO CARLIM, ET AL., defendants-appellants. BALRODGAN CO., LTD., and MAURO B. GANZON, petitioners-appellees, vs. F. A. FUENTES, ET AL., respondents-appellants.

FACTS

These consolidated cases challenge the validity of Reorganization Plan No. 20-A, dated December 10, 1956, promulgated by the Reorganization Commission under Republic Act No. 997. The specific provision under attack is Section 25, which granted the newly created Regional Offices of the Department of Labor “original and exclusive jurisdiction” over various money claims of employees, such as those for unpaid wages, overtime, separation pay, and underpayment. In each case, a Regional Office exercised this jurisdiction, heard evidence, and rendered a monetary award in favor of an employee-claimant. The employers uniformly contested these decisions, arguing that the Regional Offices, as administrative bodies, were unlawfully vested with judicial powers.
The procedural postures vary: in G.R. No. L-14837, the employer sought certiorari and prohibition directly from the Supreme Court after the Labor Standards Commission affirmed the Regional Office’s decision. In G.R. No. L-15483 and G.R. No. L-15015, the Court of First Instance of Manila granted injunctions against the enforcement of the Regional Office decisions, holding Plan No. 20-A invalid. In G.R. No. L-13940, however, the Court of First Instance, while agreeing the Plan was invalid, dismissed the employer’s complaint on the ground that the jurisdictional question was not raised before the Labor Standards Commission on appeal.

ISSUE

Whether Reorganization Plan No. 20-A, specifically Section 25 thereof which grants original and exclusive jurisdiction to Regional Offices of the Department of Labor over money claims of employees, is valid.

RULING

The Supreme Court declared Section 25 of Reorganization Plan No. 20-A null and void. The legal logic rests on the principle of non-delegation of legislative powers and the separation of powers. Republic Act No. 997, which created the Reorganization Commission, authorized it to reorganize the executive branch by grouping, consolidating, or abolishing departments and offices. Crucially, the law did not authorize the Commission to create courts or confer judicial powers upon administrative entities.
By vesting Regional Offices with “original and exclusive jurisdiction” over money claims—a function inherently judicial in nature—the Reorganization Commission effectively created inferior courts and transferred jurisdiction from the regular courts (e.g., Justice of the Peace Courts and Courts of First Instance) to an executive body. This constitutes an undue delegation of legislative power, as the legislature cannot delegate its core authority to create courts of justice or define their jurisdiction to an executive commission. Consequently, the Commission overstepped the limits of its authority under Republic Act No. 997. All decisions rendered by the Regional Offices under this invalid grant of jurisdiction are therefore null and void. The Court also clarified that the objection to a body’s lack of jurisdiction can be raised at any time and is not waived by a failure to raise it before that very body. Thus, the dismissal in G.R. No. L-13940 was reversed. The Court granted the petitions and affirmed the lower court decisions that had invalidated the Regional Offices’ actions.