GR L 59823; (August, 1982) (Digest)
G.R. No. L-59823 August 21, 1982
GETZ CORPORATION PHILS., INC., OSCAR G. BALAGOT, EDUARDO M. ORTIZ, JOSELITO M. TAN, and BEATRIZ ALO, petitioners, vs. THE COURT OF APPEALS, HON. ALEJANDRO R. BONCAROS, Presiding Judge of the Court of First Instance of Negros Oriental, Branch 1, and the SPOUSES SAMUEL ERUM and LETICIA ERUM, respondents.
FACTS
Respondent Samuel Erum, a District Manager for petitioner Getz Corporation, was terminated from employment on January 8, 1979. On March 20, 1979, he and his wife filed a complaint for Recovery of Termination Pay, Other Employment Benefits and Damages with the Court of First Instance (CFI) of Negros Oriental. Petitioners moved to dismiss, primarily on the ground of lack of jurisdiction, arguing that the claims arose from an employer-employee relationship.
The Trial Court initially dismissed the case on December 5, 1980, holding that such controversies fell under the jurisdiction of Labor Arbiters. However, upon respondent’s motion for reconsideration citing Presidential Decree No. 1367 and the case of Calderon vs. Court of Appeals, the Trial Court reinstated the case on April 9, 1981. Petitioners’ subsequent petition to the Court of Appeals was dismissed, prompting this Petition for Review to the Supreme Court.
ISSUE
Whether the regular court (Court of First Instance) has jurisdiction over the complaint for termination pay, other employment benefits, and damages filed by a dismissed employee against his employer.
RULING
The Supreme Court ruled that the regular court has no jurisdiction. The legal logic hinges on the applicable law at the time the Trial Court rendered its orders. While PD 1367, effective May 1, 1978, had removed claims for moral and other damages from Labor Arbiters’ jurisdiction, it was superseded by PD 1691, enacted on May 1, 1980. PD 1691 explicitly restored to Labor Arbiters and the National Labor Relations Commission exclusive jurisdiction over “all money claims of workers” and “all other claims arising from employer-employee relations,” which comprehensively includes claims for termination pay, benefits, and moral and exemplary damages.
Since the Trial Court’s orders of dismissal (December 5, 1980) and reinstatement (April 9, 1981) were issued after the effectivity of PD 1691, this later decree governed. Consequently, the subject matter of the complaint—claims unmistakably arising from an employer-employee relationship—fell within the exclusive original jurisdiction of the labor tribunals. The CFI therefore acted without jurisdiction. The Petition was granted, and the CFI was directed to dismiss the civil case without prejudice to the filing of the claims with the proper labor office.