G.R. No. L-18800. March 30, 1963.
VICTORIA BISCUIT CO., INC., petitioner-appellant, vs. JORGE BENEDICTO, Regional Office 3, P.G. MALIWANAG, RUBEN F. SANTOS, Labor Standards Commission, SHERIFF OF RIZAL PROVINCE and DIONISIO BANIA, respondents-appellees.

FACTS

Dionisio Bania filed a complaint for overtime and separation pay against Victoria Biscuit Co., Inc. with Regional Office No. 3 of the Department of Labor. The Hearing Officer dismissed the complaint, but on appeal, the Labor Standards Commission reversed the dismissal regarding overtime pay and awarded Bania P904.87. Victoria Biscuit appealed this Commission decision to the Court of First Instance (CFI) of Manila, docketed as Civil Case No. 43863. Instead of filing an answer, the company moved to dismiss the appeal on three grounds, primarily asserting that the Regional Office and Labor Standards Commission lacked jurisdiction over the money claim. Bania filed a manifestation joining the motion to dismiss, though not necessarily concurring with all grounds. Judge Conrado Vasquez granted the motion and dismissed the case.
Subsequently, the Labor Standards Commission issued a writ of execution to enforce its award. The sheriff garnished Victoria Biscuit’s bank account, prompting the company to file a petition for certiorari with prohibition before the Supreme Court (Civil Case No. 45930), arguing the Commission’s decision was void for lack of jurisdiction and that the CFI’s dismissal nullified it. The company deposited the award amount to lift the garnishment. The CFI later ruled that the dismissal of the appeal effectively withdrew it, thereby reviving the Commission’s decision.

ISSUE

Whether the Court of First Instance’s dismissal of the appeal revived the Labor Standards Commission’s decision, making it enforceable, despite the Commission’s alleged lack of jurisdiction over the money claim.

RULING

The Supreme Court reversed the CFI and granted the writ of certiorari, declaring the Labor Standards Commission’s decision null and void. The legal logic is anchored on the fundamental principle of jurisdiction. Citing established precedents like Corominas vs. Labor Standards Commission, the Court held that Regional Offices and the Labor Standards Commission had no jurisdiction over ordinary money claims for overtime and separation pay. Since the Commission lacked original jurisdiction, its decision was void ab initio.
The Court examined the CFI’s order of dismissal. While Bania joined the motion, the dismissal was fundamentally based on the grounds in Victoria Biscuit’s motion, chiefly the jurisdictional defect. The conformity of a party cannot confer jurisdiction where none exists by law. Jurisdiction is conferred by statute, not by consent or acquiescence of the parties. Therefore, the CFI’s dismissal, even if construed as a withdrawal of the appeal, could not validate or revive a void judgment. A nullity cannot be ratified. Consequently, the Commission’s decision remained unenforceable, and its writ of execution was issued without authority. The garnishment was improperly ordered.