GR L 17916; (April, 1963) (Digest)
G.R. No. L-17916; April 30, 1963
MAXIMO GOMEZ, plaintiff-appellant, vs. FOOKIEN TIMES COMPANY, INC., defendant-appellee.
FACTS
Maximo Gomez filed a complaint with the Department of Labor’s Regional Office against Fookien Times Company, Inc., seeking separation pay, overtime pay, and additional compensation for work on Sundays and holidays. The hearing officer dismissed the complaint. Gomez appealed to the Labor Standards Commission, which modified the decision by awarding him P781.97. Both parties gave notice of appeal, but Gomez failed to perfect his appeal within the required 30-day period, making the Commission’s order final as to him. Subsequently, Gomez filed a new complaint in the Court of First Instance of Manila seeking essentially the same reliefs. The company’s appeal from the Commission’s decision was, however, given due course and transmitted to the same court.
The Court of First Instance proceeded with the company’s appeal, heard evidence, and rendered a judgment dismissing Gomez’s complaint, finding he was dismissed for cause. Gomez then interposed the present appeal to the Supreme Court.
ISSUE
The core issue is whether the Court of First Instance validly acquired jurisdiction over the subject matter of the case, considering the proceedings originated from the Labor Standards Commission.
RULING
The Supreme Court reversed the decision of the Court of First Instance and dismissed Gomez’s complaint. The legal logic is anchored on the jurisdictional nullity of the entire administrative proceeding that preceded the court case. The Court, reiterating a long line of decisions, declared Reorganization Plan No. 20-A, specifically Section 25 which granted regional offices original and exclusive jurisdiction over money claims of laborers, to be null and void.
This invalidity stemmed from the fact that Republic Act No. 997, which created the Reorganization Commission, did not authorize the transfer of judicial jurisdiction from established courts to administrative bodies. The Constitution vests judicial power solely in the Supreme Court and such courts as established by law. The legislature cannot delegate its power to create courts or confer judicial jurisdiction to an executive body like the Reorganization Commission. Consequently, the decisions of the hearing officer and the Labor Standards Commission were declared null and void for having been rendered without jurisdiction.
Since the Court of First Instance’s decision was based solely on the appeal taken from the null and void decision of the Labor Standards Commission, it too was without legal effect. The foundation of its jurisdiction was a nullity. Therefore, all proceedings—before the hearing officer, the Labor Standards Commission, and the Court of First Instance—were declared illegal and ineffective. The proper recourse for Gomez, after the nullification of the administrative process, would have been to file his money claims originally in a court of competent jurisdiction, which he did not timely do in a procedurally effective manner following the Supreme Court’s declaration of the law.
