G.R. No. L-71552 August 30, 1988
Dra. Remedios Ortaliz-Lamayo, petitioner, vs. Felizardo G. Baterbonia, et al., respondents.

FACTS

Petitioner Dra. Remedios Ortaliz-Lamayo was appointed co-administratrix of the Intestate Estate of Jose Ortaliz, specifically for the purpose of selling Hacienda San Antonio De Padua to settle estate obligations. The hacienda was sold on March 25, 1980. Private respondents, former hacienda laborers dismissed on April 1, 1980, filed a complaint with the Ministry of Labor and Employment (MOLE) for various monetary claims covering 1977-1979 against “J. Ortaliz & Sons/Dra. Remedios Ortaliz-Lamayo.” Petitioner answered, denying being the employer and asserting the hacienda was part of the estate, with actual management under lessees Franklin and Antonio Ortaliz per lease contracts.
Instead of certifying the unresolved case to a Labor Arbiter as required by the Labor Code’s implementing rules, the MOLE Assistant Director issued an order on September 17, 1980, directing payment of the claims. This order was later affirmed by the MOLE Deputy Minister. Petitioner’s subsequent motions, highlighting the failure to refer the case to arbitration, were denied. Meanwhile, the probate court had denied the laborers’ contingent claim against the estate for being filed late and had closed the estate proceedings on December 22, 1980, after final distribution of assets. On July 19, 1985, Regional Director Felizardo Baterbonia denied petitioner’s motion and issued a writ of execution against her, prompting this certiorari petition.

ISSUE

Whether the Regional Director had jurisdiction to hear and decide the laborers’ money claims and issue the writ of execution against the petitioner.

RULING

No. The Supreme Court granted the petition, reversing and setting aside the order for the writ of execution. The Court held that the Regional Director lacked jurisdiction over the case. Under Article 217 of the Labor Code, as amended, labor arbiters have exclusive original jurisdiction over money claims arising from employer-employee relations, unless expressly excluded. The claims for unpaid wages, separation pay, and other benefits filed by the private respondents clearly fell within this exclusive jurisdiction of the Labor Arbiter. The mandatory procedure under the implementing rules required the Regional Director to certify an unsettled case to the appropriate Labor Arbiter. The Assistant Director’s failure to do so and his decision on the merits rendered the proceedings null and void ab initio for lack of jurisdiction. Consequently, the subsequent orders, including the writ of execution issued by Regional Director Baterbonia, were also nullities.
Assuming arguendo the writ was valid, it would still be unenforceable. Petitioner’s role as a special administratrix ceased when the intestate proceedings were terminated and the estate was distributed. An administratrix is a legal entity whose existence depends on the court’s order; upon the estate’s closure, that entity ceases to exist. The claims, properly directed against the alleged actual employers (the lessees), were now barred by prescription under Article 217’s three-year period for filing money claims. Thus, the order for execution was moot and academic.