GR L 71818; (August, 1986) (Digest)
G.R. No. L-71818 August 19, 1986
METROPOLITAN WATERWORKS AND SEWERAGE SYSTEM (MWSS), petitioner, vs. HON. BIENVENIDO S. HERNANDEZ, Labor Arbiter, NATIONAL LABOR RELATIONS COMMISSION, LEMUEL B. ALEGADO, DANILO S. LOPEZ, FORTUNATO L. MADRONA, ETC., ET AL., respondents.
FACTS
The Metropolitan Waterworks and Sewerage System (MWSS), a government-owned and controlled corporation, was sued before the Labor Arbiter by a group of its contractual employees for alleged non-payment of wage differentials and other monetary benefits. MWSS moved to dismiss the complaint on jurisdictional grounds, asserting that as a government corporation, its employees fall under the civil service laws and regulations, and thus the National Labor Relations Commission (NLRC) has no jurisdiction over the case. Alternatively, MWSS argued that the terms of the complainants’ employment were governed solely by their individual contracts.
The Labor Arbiter denied the motion and subsequently ruled against MWSS. The Arbiter held that while regular employees of MWSS are covered by civil service rules, its contractual or non-regular employees are not, thereby placing disputes involving the latter within the jurisdiction of the NLRC. The Arbiter further opined that the Civil Service Decree does not govern monetary claims, which instead fall under the Labor Code. MWSS then filed this petition for certiorari and prohibition to annul the Labor Arbiter’s decision and order of execution.
ISSUE
Whether the National Labor Relations Commission has jurisdiction over the monetary claims filed by contractual employees of the Metropolitan Waterworks and Sewerage System, a government-owned and controlled corporation.
RULING
The Supreme Court ruled that the NLRC has no jurisdiction. The Court, citing its precedent in National Housing Corporation vs. Juco, held that employees of government-owned or controlled corporations are governed by the civil service law and rules, not by the Labor Code. Since MWSS is indisputably a government corporation created by Republic Act No. 6234, all its employees, regardless of their employment status, are subject to the civil service regime.
The Labor Arbiter’s distinction between regular and contractual employees was rejected as without legal or logical basis. The Court explained that the civil service explicitly includes non-career service positions, such as contractual personnel hired for specific projects. Therefore, the nature of employment—whether regular or contractual—does not alter the applicable law. The Arbiter’s additional postulate that monetary claims are exempt from civil service coverage and governed by the Labor Code was deemed patently illogical and unmeritorious. Consequently, the Labor Arbiter acted without jurisdiction. The challenged decision and order were declared void and set aside, and the Labor Arbiter was enjoined to dismiss the case.