GR L 15693; (July, 1961) (Digest)
G.R. No. L-15693. July 31, 1961.
Lucia Pitogo, plaintiff-appellant, vs. Sen Bee Trading Company, Macario Tan and Sergio Tan, defendants-appellees.
FACTS
Lucia Pitogo filed a complaint in the Court of First Instance (CFI) of Cebu against Sen Bee Trading Company and its owners. She alleged that from June 5, 1952, to January 11, 1958, she was employed as a seamstress and accrued various money claims, including wage differentials, overtime pay, and vacation and sick leave pay. Despite demands, the defendants refused payment. Pitogo sought recovery of these amounts plus moral and exemplary damages totaling fifty thousand pesos.
The defendants moved to dismiss the complaint. They contended that, under Section 25 of Reorganization Plan No. 20-A, jurisdiction over such employee money claims arising from labor standards violations was vested in the Regional Offices of the Department of Labor, not the regular courts. The lower court sustained this motion and dismissed the case for lack of jurisdiction.
ISSUE
Whether the Court of First Instance correctly dismissed the complaint for lack of jurisdiction, based on Section 25 of Reorganization Plan No. 20-A, which vested original and exclusive jurisdiction over labor money claims in the regional offices of the Department of Labor.
RULING
The Supreme Court reversed the order of dismissal. The appeal directly challenged the constitutionality of Reorganization Plan 20-A, arguing that Congress cannot delegate the power to pass laws, especially those divesting regular courts of jurisdiction conferred by statute. The Court found the appeal meritorious, aligning its decision with a series of recently decided cases addressing the identical issue.
The legal logic is grounded in the non-delegability of legislative power and the interpretation of the enabling law, Republic Act No. 997 . The Court held that Congress, through RA 997, did not intend to authorize the Reorganization Commission—an executive body—to transfer jurisdictional powers from constitutional courts to administrative offices. The legislature itself cannot delegate its core power to create courts of justice or to reassign judicial jurisdiction to another government agency. Consequently, Section 25 of Reorganization Plan 20-A, which purported to grant regional offices original and exclusive jurisdiction over laborers’ money claims, was enacted without authority under RA 997 and was therefore null and void. Since the challenged provision was invalid, the CFI retained jurisdiction over Pitogo’s claims. The case was remanded to the court of origin for further proceedings.
