G.R. No. L-18182. February 27, 1963.
ALFREDO V. PEREZ, petitioner, vs. THE COURT OF INDUSTRIAL RELATIONS, and PLASTIC, INC., respondents.

FACTS

Petitioner Alfredo V. Perez was employed as a janitor by respondent Plastic, Inc. from March 14 to July 2, 1958. On July 2, 1958, he was dismissed after a company security guard apprehended him for allegedly carrying stolen plastics. A criminal case for theft was subsequently filed against Perez but was eventually dismissed. Following the dismissal of the criminal case, Perez sought reinstatement from Plastic, Inc., which was denied.
Consequently, Perez filed a petition for reinstatement with backpay before the Court of Industrial Relations (CIR). The respondent company moved to dismiss the petition on the ground that the CIR lacked jurisdiction over the subject matter. The CIR granted the motion to dismiss in an order dated September 30, 1960. Perez filed a motion for reconsideration, which was affirmed by the court en banc. Perez then appealed to the Supreme Court via certiorari.

ISSUE

Whether the Court of Industrial Relations had jurisdiction over Perez’s petition for reinstatement with backpay.

RULING

The Supreme Court ruled that the CIR correctly dismissed the petition for lack of jurisdiction. The Court explained that the jurisdiction of the CIR, following the enactment of Republic Act No. 875 (the Industrial Peace Act), is confined to specific cases: (1) labor disputes certified by the President as indispensable to the national interest; (2) controversies involving the Minimum Wage Law ( Republic Act No. 602 ); (3) cases involving hours of employment under the Eight-Hour Labor Law ( Commonwealth Act No. 444 ); and (4) cases involving unfair labor practices.
The Court clarified that its prior ruling in PRISCO vs. CIR did not grant the CIR blanket jurisdiction over all labor disputes where an employer-employee relationship exists or is sought to be re-established. The PRISCO doctrine applies specifically to claims arising under the Minimum Wage Law or the Eight-Hour Labor Law, where jurisdiction is contingent upon the existence of, or an effort to re-establish, an employer-employee relationship. In this case, Perez’s claim was merely for reinstatement based on the dismissal of the criminal charge against him. His petition did not involve the Minimum Wage Law, the Eight-Hour Labor Law, an unfair labor practice, or a presidential certification. Therefore, his cause of action fell outside the limited jurisdiction of the CIR and pertained to a matter within the competence of the regular courts. The decision of the CIR was affirmed.