GR L 25302; (March, 1968) (Digest)
G.R. No. L-25302 March 15, 1968
ABUNDIO MATILLANO, ET AL., petitioners, vs. THE HON. SEVERIANO DE LEON of the Court of Agrarian Relations, 11th Regional District and ANGEL LOCSIN, respondents.
FACTS
On April 4, 1963, twenty-three farmworkers filed a complaint before the Court of Agrarian Relations against landowner Angel Locsin. They alleged they joined a labor union on October 19, 1962, went on an unfair labor practice strike on January 18, 1963, and were refused reinstatement when they offered to return to work on March 13, 1963. They also claimed underpayment of wages, with some receiving only P1.20 per day for 150 days a year. They sought reinstatement and differential pay. After hearings, Locsin moved to dismiss on August 28, 1965, arguing the court lacked jurisdiction due to the absence of a preliminary investigation as required by Section 5(d) of Republic Act No. 875 (the Industrial Peace Act) for unfair labor practice cases. The Agrarian Court Judge, Severiano de Leon, dismissed the complaint on September 5, 1965, agreeing that the lack of a preliminary investigation was a jurisdictional defect, despite noting that the complaint involved farmworkers, not tenants. The complainants’ motion for reconsideration was denied, prompting this appeal.
ISSUE
Whether a preliminary investigation, as required under Section 5 of Republic Act No. 875 for unfair labor practice cases, is necessary before the Court of Agrarian Relations can take cognizance of a complaint filed by agricultural workers.
RULING
No. The order of dismissal is reversed and set aside. The case is remanded to the Court of Agrarian Relations for further proceedings. The Supreme Court held that at the time the complaint was filed on April 4, 1963, the applicable procedure for cases involving agricultural laborers was governed by the Rules of the Court of Agrarian Relations, which did not require a preliminary investigation. Republic Act No. 875 was not applicable to agricultural laborers at that time. Furthermore, the Court ruled that the Court of Agrarian Relations has jurisdiction over the case, including the claim for wage differentials under the Minimum Wage Law, as its charter grants it exclusive jurisdiction to enforce laws governing capital-labor relations on agricultural lands. The necessity of a preliminary investigation is a procedural matter, and the applicable rules for agricultural workers at the time of filing did not impose such a requirement.