GR L 23015 Teehankee (Digest)
G.R. No. L-23015, May 30, 1972
COLGATE-PALMOLIVE PHILIPPINES, INC., petitioner, vs. DOMINADOR DE LA CRUZ, et al., and COURT OF INDUSTRIAL RELATIONS, respondents.
FACTS
Petitioner Colgate-Palmolive Philippines, Inc. sought to annul a resolution of the Court of Industrial Relations (CIR) ordering it to pay certain monetary benefits to the respondent employees. The case originated from an unfair labor practice complaint filed by the employees. After trial, the CIR dismissed the unfair labor practice charge, finding that the employees’ dismissal was not due to union activities. However, the CIR, in the same proceeding, directed the petitioner to pay the employees the money equivalent of accrued vacation and sick leave, bonuses, and other similar benefits.
The petitioner argued that once the CIR found no unfair labor practice was committed, its jurisdiction under the Industrial Peace Act was limited to dismissing the complaint. It contended that the CIR had no authority to grant additional monetary relief, and such claims should be pursued in ordinary courts.
ISSUE
Whether the Court of Industrial Relations, in an unfair labor practice case where it finds no unfair labor practice committed, retains jurisdiction to award monetary benefits like accrued vacation and sick leave to the complaining employees.
RULING
Yes. The Supreme Court, through the concurring opinions, affirmed the CIR’s jurisdiction to award such benefits. The legal logic rests on two primary grounds. First, the Court has long rejected “split jurisdiction” in labor cases. Forcing employees to litigate related claims in separate forums is gravely prejudicial, causing wasted effort, expense, and delay. All causes of action arising from the labor dispute should be cognizable by a single court to ensure orderly administration of justice.
Second, the petitioner is estopped from questioning the CIR’s jurisdiction. The doctrine in Tijam vs. Sibonghanoy bars a party who has voluntarily submitted to a court’s jurisdiction and actively participated in the proceedings from later challenging that court’s authority after receiving an adverse decision. The CIR’s judgment ordering payment became final in 1962 without an appeal from the petitioner. Consequently, the petitioner may no longer assail the CIR’s jurisdiction or the propriety of the award at this late stage. The petition was dismissed.