Pampanga Sugar Development Co. v. Fuentes
REITERATIONFacts
The Antecedents: Respondents Pablo Abillanoza et al., employees of petitioner Pampanga Sugar Development Company, Inc. (PASUDECO), filed a complaint with Regional Office No. 3 of the Department of Labor for the collection of the balance of wages allegedly due them for work rendered on Sundays and legal holidays, with legal interest and attorney's fees. Procedural History: Petitioner filed a motion to dismiss, arguing that the complaint stated no cause of action and was barred by prior judgment and the statute of limitations due to the alleged unconstitutionality of Reorganization Plan No. 20-A. The Hearing Officer denied the motion. Petitioner's subsequent motions for reconsideration, asserting that claims under Commonwealth Act No. 444 are exclusively cognizable by the Court of Industrial Relations, were also denied. The Hearing Officer then ordered petitioner to file an answer. The Petition: Petitioner filed a petition for certiorari and prohibition to annul the proceedings and enjoin respondents from further proceeding, alleging the unconstitutionality of Reorganization Plan No. 20-A and the lack of any plain, speedy, and adequate remedy. This Court issued a preliminary injunction.
Issue(s)
Whether Section 25 of Reorganization Plan No. 20-A is valid and constitutional in granting regional offices of the Department of Labor original and exclusive jurisdiction over money claims of laborers.
Ruling
The petition is granted. The orders of the respondent officials dated September 16, October 24, and November 18, 1958, are set aside, and the preliminary injunction is made permanent. The Regional Office No. 3 of the Department of Labor is without jurisdiction to hear and decide the money claims filed by the employees.
Ratio Decidendi
On Issue 1: The Supreme Court held that the grant of original and exclusive jurisdiction to regional offices over money claims, including overtime pay and unpaid wages, is not authorized by the provisions of Republic Act No. 997. The Court emphasized that the legislature did not intend to grant the Reorganization Commission the authority to deprive the courts of jurisdiction over such claims and transfer them to administrative regional offices. Relying on the precedent set in Jose Corominas, Jr., et al. v. Labor Standards Commission, et al. (G.R. No. L-14837), the Court reaffirmed that the Commission's power was limited to administrative restructuring and did not extend to the modification of the jurisdiction of the courts. Jurisdiction over money claims arising from labor relations, specifically under Commonwealth Act No. 444 (Eight-Hour Labor Law), remains with the courts or the Court of Industrial Relations as established by existing statutes. The Court concluded that any provision in a reorganization plan that attempts to divest the judiciary of its jurisdiction without express legislative authority is null and void. Therefore, the respondent regional office officials acted without jurisdiction in entertaining the respondents' money claims.
Main Doctrine
The grant to regional offices of the Department of Labor of original and exclusive jurisdiction over money claims of laborers, including overtime pay, unpaid wages, and wages for Sundays and legal holidays, is not authorized by Republic Act No. 997, as the legislature did not intend to grant the Reorganization Commission the authority to deprive courts of jurisdiction over such claims and transfer them to regional offices.