G.R. Nos. 75746-48 December 14, 1987
ORESHOOT MINING COMPANY, petitioner, vs. HON. DIOSCORA C. ARELLANO, Director, Regional Office No. IV, MOLE, HON. VICENTE LEOGARDO, JR., Deputy Minister, MOLE, THE ACTING SHERIFF, RO No. 4, MOLE, RODRIGO BAACO, MANUEL RODRIGUEZ, MELCHOR GUMPAL et al.

FACTS

Private respondents, employees of petitioner Oreshoot Mining Company, filed complaints for illegal dismissal, reinstatement, and payment of back wages and other benefits. The cases were consolidated and adjudicated by the Regional Director of the Ministry of Labor and Employment (MOLE), who issued an Order dated October 6, 1981, directing Oreshoot to reinstate the employees and pay them monetary benefits. Oreshoot’s motions for reconsideration were denied, and the Deputy Minister affirmed the Order with modification on May 27, 1985. A writ of execution was subsequently issued.
Oreshoot filed this special civil action for certiorari, asserting that the Regional Director lacked jurisdiction over the cases. It argued that the claims for illegal dismissal, reinstatement, and monetary benefits fell within the exclusive original jurisdiction of the Labor Arbiter. Oreshoot also imputed grave abuse of discretion regarding the consolidation of cases and the ruling on the economic grounds for its business shutdown.

ISSUE

Whether the Regional Director had jurisdiction to hear and decide the complaints for illegal dismissal, reinstatement, and monetary claims filed by the employees.

RULING

The Supreme Court granted the petition, ruling that the Regional Director had no jurisdiction. The legal logic is anchored on the clear statutory delineation of jurisdiction under the Labor Code. At the time the complaints were filed, Article 217 of the Labor Code, as amended, vested original and exclusive jurisdiction in the Labor Arbiters over, inter alia, all money claims of workers and cases arising from employer-employee relations. This specifically encompasses claims for back wages, separation pay, and other benefits arising from illegal dismissal.
The Court, citing its precedent in Zambales Base Metals, Inc. vs. The Minister of Labor, emphasized that Article 217 is unambiguous. The Regional Director’s authority under Article 128 was limited to visitorial and enforcement powers to ensure compliance with labor standards. He lacked adjudicatory power over the disputed claims. His proper role was to receive the complaint, attempt conciliation, and, if unsuccessful, certify the case to the Labor Arbiter. Since the Regional Director exercised jurisdiction he did not possess, all proceedings before him, including the affirmed Orders, were null and void ab initio.
Consequently, the Court nullified the challenged Orders and writs. The complaints were remanded to the proper Labor Arbiter for appropriate proceedings. The other issues raised by Oreshoot were rendered moot by this jurisdictional ruling.