G.R. No. L-37451. July 30, 1990.
BENJAMIN L. JALANDONI, JR., petitioner, vs. WILFREDO ARSENAL and ATTORNEY JOSE Y. AGUIRRE, JR, in his capacity as Legal Officer of the NATIONAL LABOR RELATIONS COMMISSION, respondents.

FACTS

On July 9, 1973, private respondent Wilfredo Arsenal, a worker performing various agricultural tasks such as cutting sugarcane and applying fertilizer on petitioner Benjamin L. Jalandoni, Jr.’s Hacienda Malinong, filed a complaint for overtime pay before the National Labor Relations Commission (NLRC) Sub-regional Office in Bacolod City. The petitioner, upon being subpoenaed, filed a motion to dismiss the complaint, arguing that the NLRC lacked jurisdiction. He contended that the claim, arising from agrarian relations involving an agricultural worker, fell under the exclusive original jurisdiction of the Court of Agrarian Relations pursuant to the Agricultural Land Reform Code ( Republic Act No. 3844 ). The NLRC Legal Officer, respondent Atty. Jose Y. Aguirre, Jr., denied the motion to dismiss, prompting the petitioner to file this certiorari petition to challenge the NLRC’s assumption of jurisdiction.

ISSUE

The primary issue is whether the NLRC had jurisdiction over Arsenal’s money claim for overtime pay at the time it was filed in 1973.

RULING

The Supreme Court ruled that at the time the complaint was filed in 1973, jurisdiction was indeed vested in the Court of Agrarian Relations, not the NLRC. Under Section 154 of Republic Act No. 3844 , the Court of Agrarian Relations had original and exclusive jurisdiction over all money claims arising from agrarian relations. The petitioner’s hacienda was agricultural land, and Arsenal, as a farm laborer performing tasks directly related to cultivation, was an agricultural worker. His claim for overtime wages constituted an “agrarian dispute” as defined under the law, relating to the terms and conditions of employment. Therefore, the NLRC Legal Officer initially erred in not dismissing the case for lack of jurisdiction. However, the Court further ruled that the case had been overtaken by subsequent legislative changes. Beginning with the institution of the Labor Code (Presidential Decree No. 442) on November 1, 1974, and through a series of amendments culminating in Article 217 of the Labor Code, jurisdiction over all money claims of workers, whether agricultural or non-agricultural, was explicitly transferred to Labor Arbiters and the NLRC. Consequently, while the NLRC improperly assumed jurisdiction in 1973, the claim is now properly cognizable by the labor tribunal under the prevailing law. The petition for certiorari was dismissed, and the case was ordered remanded to the proper Labor Arbiter in Bacolod City for determination on the merits.