GR L 17219; (August, 1961) (Digest)
G.R. No. L-17219; August 29, 1961
SOUTHWESTERN SUGAR & MOLASSES (Far East), INC., petitioner, vs. THE COURT OF INDUSTRIAL RELATIONS and SERAPIO D. VELASCO, respondents.
FACTS
Serapio D. Velasco filed a complaint with the Court of Industrial Relations (CIR) against Southwestern Sugar & Molasses (Far East), Inc., seeking payment of overtime pay amounting to P3,844.65 and attorney’s fees. The company moved to dismiss the complaint on two grounds. First, it argued that Velasco had already released the company from any claim through an amicable settlement dated February 18, 1958, wherein he accepted P582.00 as complete satisfaction. Second, it contended that the CIR lacked jurisdiction over the subject matter, citing Supreme Court precedents.
Velasco opposed the motion, arguing the amicable settlement was null and void for violating Section 6 of Commonwealth Act No. 444 (the Eight-Hour Labor Law). He also cited the case of C. Monares vs. CNS Enterprises to support the CIR’s jurisdiction over overtime pay claims. CIR Associate Judge Amado C. Bugayong denied the motion to dismiss, ruling the settlement was for “settlement pay” in lieu of reinstatement and, if construed as payment for overtime, would be void. He also upheld the CIR’s jurisdiction. The CIR en banc affirmed this order, prompting the company to file the present petition for certiorari.
ISSUE
Whether or not the Court of Industrial Relations has jurisdiction to try and decide the complaint for overtime pay filed by Serapio D. Velasco.
RULING
The Supreme Court ruled that the CIR has no jurisdiction. The legal logic hinges on the distinction between claims where the employer-employee relationship is extant or sought to be reestablished, and claims where it is terminated with no reinstatement sought. The Court reiterated the settled doctrine that all money claims of laborers, where no reinstatement is sought and no unfair labor practice is involved, fall under the jurisdiction of the regular courts.
The Court clarified that jurisdiction is determined by the nature of the relief sought. In this case, it was undisputed that Velasco was not seeking reinstatement, and his removal was not alleged to be due to any unfair labor practice. Consequently, his claim for overtime pay had become a simple money claim following the termination of the employment relationship. The Court explained that its prior ruling in Monares, relied upon by Velasco, was inapplicable because the complainant in that case sought reinstatement in addition to overtime pay, thereby placing the claim within the CIR’s jurisdiction. Since Velasco’s complaint presented a mere money claim, the CIR acted without jurisdiction. The Resolution of the CIR en banc was declared null and void, and the complaint was ordered dismissed.
