G.R. No. L-16637; June 30, 1961
Republic Savings Bank, petitioner, vs. The Honorable, Court of Industrial Relations and Narciso Macaraeg, respondents.

FACTS

The Republic Savings Bank filed a petition seeking to enjoin the Court of Industrial Relations (CIR) from taking cognizance of a complaint filed by its former employee, Narciso Macaraeg. Macaraeg had filed Case No. 1104-V before the CIR, seeking payment of overtime pay for services rendered as a security guard from July 1955 until his separation from the bank on July 18, 1958. The complaint was purely for the recovery of a monetary claim.
The bank moved to dismiss the case on the ground that the CIR lacked jurisdiction. The hearing judge, Associate Judge Emiliano C. Tabigne, granted the motion to dismiss. However, upon Macaraeg’s motion for reconsideration, the majority of the CIR en banc reversed the order of dismissal and remanded the case for trial on the merits. The bank then elevated the matter to the Supreme Court via the present petition.

ISSUE

Whether the Court of Industrial Relations had jurisdiction to entertain Narciso Macaraeg’s complaint for overtime pay after his separation from employment, where no claim for reinstatement was involved.

RULING

The Supreme Court granted the petition, ruling that the CIR had no jurisdiction over the case. The legal logic is anchored on the jurisdictional delineation established by Republic Act No. 875 (the Industrial Peace Act) and Republic Act No. 602 (the Minimum Wage Law). The Court, through a long line of decisions, had consistently held that under Republic Act No. 875, the CIR no longer possessed jurisdiction over simple money claims. Such claims were expressly vested in the ordinary courts by Section 16 of Republic Act No. 602.
The Court acknowledged an exception to this rule: the CIR retained jurisdiction over money claims if the employee continued in service or sought reinstatement, as the claim would then be incidental to the labor dispute concerning employment relations. The respondent court relied on Monares vs. C.H.S. Enterprises, but that case was distinguishable because the complaint therein included a demand for reinstatement alongside monetary claims.
In the instant case, Macaraeg had already been separated from service at the time he filed his complaint, and he made no allegation that his separation was illegal nor did he seek reinstatement. His action was, therefore, a pure money claim for overtime pay, unconnected to any ongoing employment relationship or dispute over continued service. Consequently, jurisdiction properly pertained to the regular courts. The Supreme Court set aside the CIR’s order and dismissed the case, without prejudice to Macaraeg’s right to file his claim in a competent court of general jurisdiction.