GR L 57032; (June, 1982) (Digest)
G.R. No. L-57032, June 19, 1982
CARDINAL INDUSTRIES, INC. vs. HON. AMADOR T. VALLEJOS and MANUEL Z. RAMOS
FACTS
Petitioner Cardinal Industries, Inc. employed private respondent Manuel Z. Ramos as a rebar foreman for a project in Iraq under a one-year contract. In November 1980, petitioner terminated Ramos’s employment. Ramos subsequently filed a complaint for a sum of money and damages before the Court of First Instance of Manila. His claims included payment of salaries for the unexpired portion of his contract, various benefits, and substantial amounts for moral, exemplary, nominal damages, and attorney’s fees.
Petitioner moved to dismiss the case, asserting that jurisdiction properly belonged to the Bureau of Employment Services (now the Philippine Overseas Employment Administration) under Article 15 of the Labor Code, as amended by Presidential Decree No. 1691. This provision grants the labor agency exclusive original jurisdiction over money claims and cases arising from employer-employee relations involving overseas Filipino workers. Respondent Judge denied the motion to dismiss, relying on the precedent in Calderon vs. Court of Appeals, which suggested that claims for damages could fall under regular court jurisdiction.
ISSUE
Whether the regular court or the labor agency has jurisdiction over a complaint for damages and money claims arising from the premature termination of an overseas employment contract.
RULING
The Supreme Court ruled in favor of the petitioner, holding that jurisdiction is vested in the labor agency. The Court clarified that private respondent’s claims for unpaid salaries and damages undeniably arose from employer-employee relations connected to overseas employment. These claims fall squarely within the original and exclusive jurisdiction of the regional offices of the Ministry of Labor (now the Department of Labor and Employment) as mandated by Article 15(b) of the Labor Code, as amended by P.D. 1691.
The Court distinguished and deemed inapplicable the Calderon ruling cited by the respondent Judge. The Calderon case was decided under the regime of P.D. 1367, which had specifically divested Labor Arbiters of jurisdiction over claims for moral and other forms of damages. However, P.D. 1691, which was already in effect when Ramos filed his complaint, had superseded P.D. 1367. This subsequent law, along with Batas Pambansa Blg. 130, restored the jurisdiction of labor arbiters and the National Labor Relations Commission over all money claims and all other claims arising from employer-employee relations, including claims for moral and exemplary damages. Consequently, the Calderon precedent was no longer controlling. The Petition was granted, and the respondent Judge was directed to dismiss the civil case without prejudice to the filing of the claims with the proper labor agency.