G.R. No. L-17285; July 31, 1963
EDUARDO ELCHICO, in his capacity as heir of the late Jose Elchico and as administrator of the latter’s estate, petitioner, vs. COURT OF INDUSTRIAL RELATIONS, PEDRO GABRIEL, PACIFICO ALMAZAR, LAZARO GUTIERREZ, PEDRO DE LA PAZ, FRANCISCO ESQUIVEL and FELIMON DE GUZMAN, respondents.

FACTS

The case originated from a petition filed by the respondent employees with the Court of Industrial Relations (CIR) in 1958 to recover overtime and separation pay from the New Angat-Manila Transportation and its manager, Florencio Elchico. The transportation company was part of the estate of the late Jose Elchico, then under judicial settlement in the Court of First Instance of Rizal, with petitioner Eduardo Elchico serving as the duly appointed administrator. After trial, the CIR rendered an amended decision ordering the company and its manager to pay the claimants the total sum of P30,500.69. The employer company and manager appealed this decision to the Supreme Court in G.R. No. L-16283.
While that appeal was pending, the respondent employees filed a motion in the CIR to compel the employer to deposit the award amount. On July 22, 1960, the CIR issued the order subject to this certiorari proceeding, directing the New Angat-Manila Transportation and Florencio Elchico to deposit P30,500.69 or post a bond for that sum pending appeal. Subsequently, on December 27, 1960, the Supreme Court rendered its decision in the related appeal, G.R. No. L-16283.

ISSUE

Whether the CIR order requiring a deposit of the monetary award pending appeal remains valid and enforceable after the Supreme Court, in a related decision, set aside the underlying CIR award for lack of jurisdiction.

RULING

The Supreme Court set aside the CIR order. The legal logic is anchored on the final and controlling effect of the Supreme Court’s prior decision in G.R. No. L-16283. In that decision, the Court ruled that the CIR lacked jurisdiction over the employees’ money claim. The claimants were dismissed and did not seek reinstatement; they merely sought recovery of overtime and separation pay. Following precedent, such a pure money claim, where no reinstatement is sought, falls within the jurisdiction of regular courts, not the CIR. Consequently, the Supreme Court set aside the CIR’s amended decision and resolution, explicitly without prejudice to the refiling of an appropriate action in the proper court.
Given this dispositive ruling, the foundational award upon which the deposit order was based was nullified. The CIR’s jurisdiction to issue ancillary orders, like the deposit directive, is derivative of its jurisdiction over the main case. Once the main decision was vacated for lack of jurisdiction, the ancillary order lost its legal basis and could no longer stand. The Supreme Court, therefore, logically extended the effect of its prior jurisdictional ruling to this related proceeding, setting aside the deposit order as moot and without legal foundation. The ruling emphasizes that procedural orders dependent on a void judgment share the fate of that judgment.