GR L 65505; (October, 1987) (Digest)
G.R. No. L-65505 October 12, 1987
GABRIEL ABAD, ET AL., petitioners, vs. REGIONAL TRIAL COURT OF MANILA, BRANCH LII-HON. DAVID G. NITAFAN and THE PHILIPPINE AMERICAN GENERAL INSURANCE COMPANY, INC., respondents.
FACTS
The petitioners, former employees of respondent Philippine American General Insurance Company, Inc. (PHILAMGEN), filed a complaint in 1978 for the payment of the money value of their accumulated sick leave. The then Court of First Instance (CFI) initially dismissed the complaint, but the Supreme Court, in G.R. No. L-50563 (1981), set aside the dismissal and ordered the CFI to conduct further proceedings. The case was remanded and, after reconstitution of records lost in a fire, was renumbered.
Following the judicial reorganization under Batas Pambansa Blg. 129, the case was re-raffled to the respondent Regional Trial Court (RTC). The RTC, presided by Judge David G. Nitafan, motu proprio dismissed the complaint. It ruled that it lacked jurisdiction over the subject matter, holding that money claims arising from employer-employee relations fell under the exclusive original jurisdiction of labor arbiters as provided in the Labor Code, and that the judicial reorganization abolished the former CFI and its initially acquired jurisdiction.
ISSUE
Whether the Regional Trial Court correctly dismissed the complaint for lack of jurisdiction over the petitioners’ money claims.
RULING
The Supreme Court denied the petition and affirmed the RTC’s dismissal. The Court explained that while the principle of adherence of jurisdiction generally means that once a court acquires jurisdiction, it retains it until final resolution, this rule yields when the change in jurisdiction is curative in character. The judicial reorganization under B.P. Blg. 129 was such a curative change. It abolished the former Courts of First Instance and redefined the jurisdiction of the Regional Trial Courts that replaced them.
Crucially, Section 19 of B.P. Blg. 129, defining RTC jurisdiction, now included a new paragraph (6) granting it jurisdiction only in “all cases not within the exclusive jurisdiction of any court, tribunal, person or body exercising judicial or quasi-judicial functions.” The petitioners’ money claims for sick leave benefits are clearly money claims of workers arising from employer-employee relations. Under Article 217 of the Labor Code, as amended, such claims fall under the exclusive original jurisdiction of labor arbiters, not the regular courts. Therefore, the RTC correctly held that it lacked jurisdiction. The dismissal is without prejudice to the petitioners filing their claims before the proper labor tribunals.