G.R. No. L-14999 December 30, 1961
NARIC WORKERS’ UNION, petitioner, vs. COURT OF INDUSTRIAL RELATIONS and NATIONAL RICE AND CORN CORPORATION, respondents.

FACTS

In Case No. 746-V, the Court of Industrial Relations (CIR) issued an Order on November 10, 1952, enjoining the NARIC from dismissing any employee without just cause and without the court’s express authority, pending the dispute’s settlement. On December 27, 1953, NARIC dismissed its warehouseman, Bienvenido Hementera, for alleged irregularity. Almost three years later, on November 16, 1956, the Naric Workers’ Union filed a petition for Hementera’s reinstatement, alleging his dismissal violated the 1952 injunctive order.
The CIR dismissed the petition. It ruled it lacked jurisdiction, noting Hementera was a non-union employee at a provincial branch and was thus not among the personnel involved in the original Manila-based dispute. The union’s motion for reconsideration was denied, prompting this petition for review, which argues the CIR acted with grave abuse of discretion. The union contended the dismissal violated the court’s order and Civil Service rules, as NARIC employees were under civil service.

ISSUE

Whether the Court of Industrial Relations committed grave abuse of discretion in dismissing the petition for Hementera’s reinstatement.

RULING

The Supreme Court dismissed the petition, affirming the CIR’s order. The legal logic rests on two primary grounds: the absence of a cause of action due to prescription/laches and the CIR’s lack of jurisdiction over the subject matter.
First, Hementera’s claim was time-barred. If he was a civil service eligible, his action for reinstatement prescribed in one year from his 1953 dismissal. If not under civil service, laches had set in due to the nearly three-year delay in filing the petition. The Court rejected the claim that illness justified the delay, noting it was implausible he was incapacitated for the entire period. The fixed period is a condition precedent for a cause of action; its lapse extinguishes the right to sue.
Second, the CIR correctly declared it lacked jurisdiction. The Court clarified the CIR’s jurisdiction was limited to specific cases: (1) certified national interest labor disputes, (2) minimum wage controversies, (3) hours of employment disputes, and (4) unfair labor practice cases. Hementera’s petition was a simple reinstatement and back wages claim arising from an alleged wrongful dismissal. Since no unfair labor practice was claimed, the case involved a mere breach of contractual obligation or a possible violation of Civil Service rules—matters within the exclusive jurisdiction of ordinary courts. Furthermore, the union lacked legal capacity to sue on behalf of Hementera, a non-member, as it was not the real party in interest. Thus, the CIR did not err in dismissing the petition.