G.R. No. L-18554, December 27, 1962
American Oxygen & Acetylene Company, Inc. vs. Court of Industrial Relations and Isidro Natavio

FACTS

Respondent Isidro Natavio filed a petition with the Court of Industrial Relations (CIR) against petitioner American Oxygen & Acetylene Company. He alleged employment from 1948 to 1958, separation due to illness, and pending compensation claims before a Regional Office of the Department of Labor. His core complaint sought unpaid overtime and holiday pay for work rendered from 1949 to 1956. The petitioner moved to dismiss, contesting the CIR’s jurisdiction, arguing prescription, and noting the pending regional office claim.
Natavio subsequently filed an amended petition without prior court leave while the motion to dismiss was pending. The amendments crucially altered the periods for overtime and holiday claims to extend through 1958 and added an allegation that the company refused to reinstate him upon being pronounced cured. The CIR trial judge initially dismissed the case, finding the employer-employee relationship terminated and an insufficient number of laborers involved. However, the CIR en banc, upon reconsideration, set aside the dismissal and gave due course to the amended petition.

ISSUE

Whether the Court of Industrial Relations acquired jurisdiction over Natavio’s claims through his amended petition.

RULING

The Supreme Court ruled that the CIR did not acquire jurisdiction. The Court emphasized that jurisdiction is determined by the allegations in the original petition at the time of filing. Natavio’s original petition essentially sought monetary claims for overtime and holiday pay from a former employer, with the employment relationship having ceased years prior. Such a claim for mere money due, absent a concurrent demand for reinstatement indicative of an existing employer-employee relationship, falls under the jurisdiction of regular courts, not the CIR.
The attempted amendment, filed without leave and while a jurisdictional challenge was pending, was a sham device to circumvent this jurisdictional defect. The amendments, particularly the new reinstatement allegation, were inserted precisely to fabricate a basis for CIR jurisdiction. The Court, citing Campos Rueda Corporation vs. Bautista, held that a complaint cannot be amended to confer jurisdiction if the cause of action originally pleaded was outside the court’s authority. The original petition’s deficiencies were jurisdictional and incurable by amendment. Consequently, the CIR en banc erred in reinstating the case. The Supreme Court granted the writ, set aside the CIR order, and directed the dismissal of Natavio’s original petition.