G.R. No. L-27757 March 28, 1968
RICARDO DEQUITO, plaintiff-appellant, vs. LEOPOLDO LOPEZ, AND/OR MARIA N. LOPEZ, ENRIQUE LOPEZ, SALVADOR LOPEZ, JR., RODOLFO LOPEZ AND FLORDELIZ LOPEZ IÑIGO, AS CO-HEIRS AND/OR CO-OWNERS OF LOPEZ ESTATE, defendants-appellees.

FACTS

Plaintiff-appellant Ricardo Dequito was employed as a security guard by defendants-appellees, the co-heirs/co-owners of the Lopez Estate, in their agricultural enterprise in Davao from November 11, 1958, until his dismissal on July 11, 1963. Dequito filed a complaint in the Court of First Instance seeking recovery of: (1) separation pay; (2) pay differential; and (3) overtime pay, along with claims for exemplary damages and reimbursement of expenses. The defendants-appellees filed a motion to dismiss, contending that the Court of First Instance lacked jurisdiction. They argued that under the Agricultural Land Reform Code (Republic Act No. 3844), the Court of Agrarian Relations had original and exclusive jurisdiction over money claims arising from agrarian relations, given that Dequito was a former employee of an agricultural enterprise. The lower court sustained this contention and dismissed the case for lack of jurisdiction.

ISSUE

Whether the Court of First Instance or the Court of Agrarian Relations has jurisdiction over the money claims (separation pay, pay differential, overtime pay) filed by a security guard employed in an agricultural enterprise.

RULING

The Supreme Court ruled that the Court of First Instance has jurisdiction. The order of dismissal was set aside and the case was remanded to the lower court for further proceedings. The Court held that while the defendants-appellees operated an agricultural enterprise, the plaintiff-appellant’s employment as a security guard and the money claims arising from his dismissal did not constitute “agrarian relations” as contemplated under the Agricultural Land Reform Code. The work of a security guard lacks the essential element that would bring it within the scope of agrarian relations, which typically involve the relationship between a proprietor and tenants, lessees, or agricultural workers. The grant of exclusive jurisdiction to the Court of Agrarian Relations is based on its presumed expertise in agrarian disputes, which does not extend to claims of a security guard. The statutory provision (Section 154) vesting jurisdiction in the Court of Agrarian Relations over “money claims arising from agrarian relations” is not susceptible to an interpretation that would include such employment. The Court applied the law literally, as there was no need for interpretation. The Court also denied a belated motion to dismiss the appeal filed by the defendants-appellees, noting the constitutional and statutory mandates for the protection of labor and the promotion of social justice.