GR L 71907; (July, 1987) (Digest)
G.R. No. L-71907; July 30, 1987
EDI-STAFF BUILDERS INTERNATIONAL, INC., petitioner, vs. HON. VICENTE LEOGARDO, JR., DEPUTY MINISTER OF LABOR AND EMPLOYMENT, HON. SEVERO PUKAN, REGIONAL DIRECTOR, NCR, MINISTRY OF LABOR & EMPLOYMENT, and TERESITA B. BERNARDO, respondents.
FACTS
Private respondent Teresita B. Bernardo was employed by petitioner EDI-Staff Builders International, Inc., a recruitment agency, on December 1, 1977. She received successive promotions and salary increases, ultimately attaining the position of Senior Supervising Consultant by September 1, 1980. On January 19, 1981, her employment was terminated. On February 12, 1981, Bernardo filed a complaint for illegal dismissal with the Regional Director of the Ministry of Labor and Employment, National Capital Region.
The Regional Director assumed jurisdiction, required the submission of position papers, and subsequently rendered a decision on August 11, 1982, declaring the dismissal illegal and ordering reinstatement with full back wages. The Deputy Minister affirmed this decision on February 25, 1985, modifying the back wages to a period of three years. Petitioner moved for reconsideration, challenging the Regional Director’s jurisdiction to summarily decide the case, arguing it should have been endorsed to a Labor Arbiter under Article 217 of the Labor Code. The motion was denied.
ISSUE
Whether or not the Regional Director and the Deputy Minister of Labor had jurisdiction to summarily decide the complaint for illegal dismissal filed by private respondent.
RULING
The Supreme Court ruled that the public respondents acted within their jurisdiction. The petition is devoid of merit. Petitioner’s reliance on Article 217 of the Labor Code, as amended by Batas Pambansa Blg. 130, which vests exclusive jurisdiction over termination cases in Labor Arbiters, is misplaced. This amendment took effect only on August 21, 1981. The complaint was filed on February 12, 1981; thus, the law and implementing rules in force at that time governed jurisdiction.
Pursuant to the then-prevailing Policy Instruction No. 6 issued by the Ministry of Labor, Regional Directors had exclusive original jurisdiction over termination cases, including complaints for illegal dismissal. This was affirmed in the case of Cebu Institute of Technology vs. Minister of Labor. The Regional Director was fully authorized to summarily investigate and decide the case, as he did. The Court also found no merit in petitioner’s claim of valid dismissal due to loss of confidence, upholding the labor officials’ factual finding that the alleged grounds were vague, unsubstantiated, and contradicted by the series of promotions and salary increases granted to the employee. The findings of fact by labor officials, supported by substantial evidence, are conclusive. The assailed decision was affirmed and the petition dismissed.