GR L 18556; (March, 1963) (Digest)
G.R. No. L-18556; March 29, 1963
JUAN ANDAN and ASUNCION CRUZ-ANDAN, petitioners-appellants, vs. THE SECRETARY OF LABOR, JULIANO ESTRELLA, EUGENIO AGUIRRE, FERNANDO NAVARRO, ET AL., respondents-appellees.
FACTS
Petitioners Juan Andan and Asuncion Cruz-Andan were previously charged criminally for violating labor laws. After a joint trial in 1958, Asuncion Cruz was convicted and fined, while Juan Andan was acquitted. Subsequently, in November 1958, the private respondents filed a complaint for unpaid wages and overtime pay against the petitioners before Regional Office No. 3 of the Department of Labor. The petitioners moved to dismiss the complaint on the grounds of res judicata, arguing the prior criminal judgment barred the civil claim, and lack of jurisdiction of the regional office. The Hearing Officer denied the motion and, after trial, rendered a decision ordering the petitioners to pay a substantial sum for overtime and unpaid wages, plus attorney’s fees.
The petitioners then filed a petition for certiorari and prohibition with the Court of First Instance of Bulacan, seeking to annul the regional office’s proceedings and decision. The lower court initially issued a preliminary injunction but ultimately dismissed the petition, upholding the regional office’s jurisdiction and rejecting the defense of res judicata. The petitioners appealed this dismissal to the Supreme Court.
ISSUE
The primary issue is whether Regional Office No. 3 of the Department of Labor had jurisdiction to hear and adjudicate the private respondents’ money claims for unpaid and overtime wages.
RULING
The Supreme Court reversed the lower court’s decision, ruling that Regional Office No. 3 lacked jurisdiction over the money claims. The legal logic is anchored on the invalidity of the jurisdictional grant under Reorganization Plan No. 20-A. The Court, citing its joint decision in several prior cases (including Corominas, Jr. vs. Labor Standards Commission), held that Section 25 of Reorganization Plan No. 20-A, which purported to grant regional offices original and exclusive jurisdiction over money claims, was not authorized by its enabling law, Republic Act No. 997. Since the grant of power to the Reorganization Commission under RA 997 did not include the authority to confer such adjudicatory jurisdiction on administrative regional offices, the provision was ultra vires and void.
Consequently, Regional Office No. 3 acted without legal authority. All proceedings conducted, including the decision ordering payment and the subsequent orders for execution, were declared null and void. Having resolved the case on the fundamental jurisdictional defect, the Supreme Court found it unnecessary to address the ancillary issue of whether the defense of res judicata was applicable to the administrative complaint. The judgment of the regional office was set aside.