G.R. No. L-16283, December 27, 1960
NEW ANGAT-MANILA TRANSPORTATION and EDUARDO ELCHICO, in his capacity as heirs of the deceased Jose Elchico and as administrator of the latter’s estate, petitioners, vs. COURT OF INDUSTRIAL RELATIONS, PEDRO GABRIEL, PACIFICO ALMAZAR, LAZARO GUTIERREZ, PEDRO DE LA PAZ, FRANCISCO ESQUIVEL and FILEMON DE GUZMAN, respondents.

FACTS

The respondents (employees) filed a petition in the Court of Industrial Relations (CIR) against the petitioners (employer) for the recovery of overtime compensation and separation pay. The employees had been dismissed from their employment in 1958. In their petition, they did not seek reinstatement to their former positions but only asked for the collection of overtime pay and termination pay. The petitioners (respondents in the CIR) raised the defense, among others, that the claims should be filed in the regular courts or in the testate/intestate proceedings of the deceased employer’s estate. The CIR trial judge rendered a decision, later amended, ordering the payment of the overtime compensation (except for one claim) and separation pay. The petitioners filed a motion for reconsideration, which was denied by the CIR en banc for being filed beyond the reglementary period. The petitioners then sought a review of the CIR’s decision and resolution by certiorari.

ISSUE

Whether or not the Court of Industrial Relations had jurisdiction over the claims for overtime pay and separation pay filed by employees who were already dismissed and who were not seeking reinstatement.

RULING

The Supreme Court set aside the decision and resolution of the Court of Industrial Relations. Applying the principle established in Price Stabilization Corporation vs. Court of Industrial Relations, the Court held that the CIR’s jurisdiction over claims arising from employment, such as those under the Minimum Wage Law and the Eight-Hour Labor Law, exists only when the employer-employee relationship is still existing or when its wrongful severance is sought to be remedied through reinstatement. After the termination of the relationship and when no reinstatement is sought, such claims become mere money claims and fall within the jurisdiction of the regular courts. Since the respondent-employees were dismissed and did not seek reinstatement, their petition for overtime and separation pay constituted mere money claims. Consequently, the case should have been filed in the regular courts or the appropriate probate court. The Supreme Court did not find it necessary to rule on the other assigned errors. The dismissal was without prejudice to the refiling of the appropriate action in the proper court.