G.R. No. L-15370; May 31, 1961
Emilio Dableo, plaintiff-appellee, vs. Luzon Stevedoring Co., Inc., defendant-appellant.

FACTS

Emilio Dableo, a former deckhand, filed a pauper’s action in the Court of First Instance of Manila to collect unpaid overtime compensation for services rendered in 1950, 1952, 1953, and 1954. The defendant, Luzon Stevedoring Co., Inc., denied the claim, asserting all overtime had been properly paid, and filed a counterclaim for damages. The parties stipulated that Dableo rendered overtime on 364 nights, but left the specific number of hours per night for further proof. After trial, the lower court found that “one night” and “one-half night” of overtime equated to eight and four hours, respectively. It awarded Dableo a balance of P1,319.36 after deducting a “coffee money allowance” and held a release he signed was not entirely binding.
The defendant appealed. The Court of Appeals, however, certified the appeal to the Supreme Court, questioning the lower court’s jurisdiction. It posited that a claim for overtime compensation by a laborer fell within the exclusive jurisdiction of the Court of Industrial Relations (CIR), not the regular courts.

ISSUE

The primary issue is whether the Court of First Instance had jurisdiction over Dableo’s money claim for overtime pay. A secondary issue involves the correctness of the trial court’s factual findings on the hours of overtime worked.

RULING

The Supreme Court held that the Court of First Instance correctly exercised jurisdiction. The ruling clarified the jurisdictional delineation between the CIR and regular courts concerning money claims arising from employment. The Court reiterated the settled doctrine that the CIR’s jurisdiction extends to cases where the employer-employee relationship is still existing or where its wrongful severance is contested and reinstatement is sought. In such instances, all connected claims, like those under the Eight-Hour Labor Law, fall under CIR competence.
Conversely, where the employment relationship has already been terminated and the employee does not seek reinstatement, as in Dableo’s case, the claim is transformed into a simple money claim for a sum of money. It ceases to be an industrial dispute requiring the CIR’s specialized intervention and becomes a matter within the general jurisdiction of the regular courts. Since Dableo had already left service and only sought payment, his action was properly filed in the Court of First Instance.
Regarding the substantive appeal on the factual findings (e.g., the number of hours constituting “one night”), the Supreme Court declined to rule on the merits. It noted that the appellant’s challenge required a review of the evidence, and the amount involved was less than P200,000. Consequently, pursuant to the Judiciary Act, the Court remanded the case to the Court of Appeals for appropriate review and judgment on the factual issues raised.