GR L 15371; (July, 1961) (Digest)
G.R. No. L-15371; July 31, 1961
Marcelo Liwanag, plaintiff-appellant, vs. Central Azucarera Don Pedro, defendant-appellee.
FACTS
Plaintiff-appellant Marcelo Liwanag filed a claim for overtime pay, nighttime pay, and vacation leave pay against his employer, Central Azucarera Don Pedro. He initially filed this action with the Court of Industrial Relations, but it was dismissed for lack of jurisdiction. Subsequently, on October 8, 1956, Liwanag filed the same claim with the Court of First Instance (CFI) of Batangas. The defendant company answered the complaint.
On February 5, 1958, the defendant moved to dismiss the action, contending that the CFI no longer had jurisdiction. The company argued that under Section 25 of Reorganization Plan No. 20-A, exclusive and original jurisdiction over such money claims for services had been conferred upon the regional offices of the Department of Labor. The lower court granted the motion to dismiss, prompting Liwanag’s direct appeal to the Supreme Court on a pure question of law.
ISSUE
Whether the Court of First Instance or the regional office of the Department of Labor has jurisdiction over the appellant’s money claim for overtime, nighttime, and vacation leave pay.
RULING
The Supreme Court ruled in favor of the appellant, Marcelo Liwanag, and set aside the order of dismissal. The Court held that the CFI retained jurisdiction over the case. The legal logic centered on the validity of the jurisdictional grant in Reorganization Plan No. 20-A. The Court found that Section 25 of said Plan, which purported to grant regional labor offices exclusive original jurisdiction over money claims, was null and void.
This conclusion was based on the principle that the Government Survey and Reorganization Commission, created under Republic Act No. 997 , did not possess the authority to transfer judicial functions from the courts to an executive body. The Commission’s mandate was limited to reorganizing the executive branch, not to diminishing or reallocating the judicial power vested by law in the courts of justice. The Plan, therefore, constituted an invalid executive encroachment on judicial jurisdiction. The Court cited its recent and consistent rulings in analogous cases, such as Corominas, Jr. v. Labor Standards Commission, to support this doctrine. Consequently, the case was remanded to the Court of First Instance of Batangas for further proceedings.