GR L 72074; (April, 1987) (Digest)
G.R. No. L-72074. April 30, 1987.
ATLAS FERTILIZER CORPORATION, petitioner, vs. HON. EXALTACION NAVARRO in her capacity as Presiding Judge of Branch XX of the Regional Trial Court of Cebu, and EMILIANO BELLEZA, respondents.
FACTS
Private respondent Emiliano Belleza was employed by petitioner Atlas Fertilizer Corporation. On December 26, 1978, he was advised of his impending termination. He submitted a resignation letter on January 4, 1979, to take effect on February 15, 1979. However, on January 8, 1979, he was also asked to explain why he should not be terminated for cause. On January 22, 1979, Belleza filed a complaint for injunction with damages in the Regional Trial Court (RTC) to prevent his termination, arguing his resignation rendered any termination unlawful. The petitioner accepted the resignation effective February 15, 1979. A related labor case was filed, and the Department of Labor ultimately found the severance of employment in order and denied separation pay.
ISSUE
Whether the regular court (RTC) retained jurisdiction over the case for damages arising from employer-employee relations after the enactment of Presidential Decree No. 1691, which transferred jurisdiction over such money claims to the National Labor Relations Commission (NLRC).
RULING
The Supreme Court ruled that the RTC lost jurisdiction and must dismiss the case. The legal logic hinges on the application of a statutory change in jurisdiction during the pendency of the suit. While a general rule exists that jurisdiction once acquired continues until final termination, an exception applies when a new statute expressly or by clear implication divests the court of jurisdiction over pending cases. At the time of filing in January 1979, Presidential Decree No. 1367 was in effect, which allowed courts to hear claims for damages arising from employer-employee relations. However, Presidential Decree No. 1691, enacted on May 1, 1980, during the pendency of the case, transferred exclusive jurisdiction over “all money claims of workers,” including separation pay and other benefits, to the NLRC. The Court construed this amendatory decree as intended to operate on actions pending before its enactment, thereby divesting the RTC of jurisdiction. The policy rationale is to centralize expertise in labor tribunals for the prompt resolution of employer-employee disputes. The petition was granted, and the RTC was directed to dismiss the civil case without prejudice to refiling with the proper labor agency.