GR L 19526; (September, 1965) (Digest)
G.R. No. L-19526 September 20, 1965
Case Parties: ATLANTIC, GULF AND PACIFIC COMPANY OF MANILA, INC., Administrator for the P.I. MECHANICAL LOADING SYSTEM PROJECT, petitioner, vs. HILARION OLIVAR and HON. JOSE S. BAUTISTA, ET AL., as Judges of the Court of Industrial Relations, respondents.
FACTS
In June 1961, respondent Hilarion Olivar filed a complaint with the Court of Industrial Relations (CIR) against petitioner Atlantic, Gulf and Pacific Company of Manila, Inc. Olivar alleged he was dismissed from his job as a watchman without cause. His prayer sought reinstatement to his former position, payment of back wages from the time of his dismissal until reinstatement, moral damages, and attorney’s fees. The complaint contained no allegations of a labor dispute, unfair labor practice, or a fixed term of employment. The petitioner company moved to dismiss the case for lack of jurisdiction, but the CIR denied the motion and a subsequent motion for reconsideration. The company then elevated the matter to the Supreme Court via a special civil action, challenging the CIR’s jurisdiction.
ISSUE
Whether or not the Court of Industrial Relations had jurisdiction over Hilarion Olivar’s complaint for illegal dismissal, which sought reinstatement and back wages, but did not involve allegations of unfair labor practice, a certified labor dispute, or violations of the Minimum Wage Law or the Eight-Hour Labor Law.
RULING
The Supreme Court ruled that the Court of Industrial Relations had NO jurisdiction over the case. The Court granted the writ, reversing the CIR’s order.
The Court held that Olivar’s claim, as framed in his complaint, was a simple action for illegal dismissal seeking reinstatement and back wages. The Court emphasized that the CIR’s jurisdiction was limited to specific cases, such as those involving unfair labor practices, labor disputes certified by the President, or violations of labor standards laws like the Minimum Wage Law or the Eight-Hour Labor Law. Since Olivar’s complaint contained no allegations falling under any of these specific categories, his claim was considered a mere money claim that fell under the jurisdiction of the regular courts. The Supreme Court cited several precedents (Campos v. Manila Railroad Co., San Miguel Brewery, Inc. v. Floresca, Perez v. CIR & Plastics, Inc., among others) which consistently held that a simple action for reinstatement and back wages, without more, is not within the CIR’s jurisdiction.