Ruiz v. Pastor
REITERATIONFacts
The Antecedents: Vicente Carin and twenty-five others filed a complaint with the Department of Labor, Regional Office No. VI, Cebu City, against Agusan Mindanao Timber Corporation, Nasipit Lumber Company, Olivo Ruiz (President of Nasipit Stevedoring Corporation), Bonifacio Ignacio (Treasurer of Nasipit Labor Union), and Rodolfo Bataliones (Treasurer of Nasipit Labor Union), for the recovery of shares and back wages amounting to P23,781.00. Procedural History: On February 24, 1958, Cedar V. Pastor of the Regional Office rendered judgment ordering Olivo Ruiz to pay the claimants the total amount of P23,781.00. A motion for reconsideration filed by Ruiz was denied. Subsequently, Ruiz filed a petition for Certiorari and Prohibition with Preliminary Injunction with the CFI of Cebu, assailing the validity of Reorganization Plan No. 20-A, specifically Section 25, which granted regional offices original and exclusive jurisdiction over claims arising from violations of labor standards. The CFI upheld the constitutionality of Reorganization Plan No. 20-A and denied the writ. The Petition: This is an appeal from the judgment of the CFI of Cebu.
Issue(s)
Whether Reorganization Plan No. 20-A, specifically Section 25 thereof, is valid in granting original and exclusive jurisdiction to Regional Offices of the Labor Department over claims of laborers arising from violations of labor standards on working conditions. Whether the Hearing Officer had jurisdiction to adjudicate the claim of Vicente Carin and his companions.
Ruling
The decision appealed from is hereby set aside and another entered, dismissing the case (not the appeal), without prejudice to its ventilation with the proper court. No costs.
Ratio Decidendi
On the validity of Reorganization Plan No. 20-A, Section 25: The Supreme Court reiterated its ruling in previous cases, specifically Cagalawan vs. Customs Canteen, et al., G.R. No. L-16031, October 31, 1961, and other cited cases, declaring Section 25 of Reorganization Plan No. 20-A null and void. The Court emphasized that Congress, in enacting Rep. Act No. 997, did not intend to authorize the transfer of powers and jurisdiction granted to courts of justice to officials or offices created by a Reorganization Plan. The Legislature cannot delegate its powers to create courts of justice to any other agency of the Government. Therefore, the grant of original and exclusive jurisdiction to regional offices over money claims of laborers, as provided in Section 25 of Reorganization Plan No. 20-A, was made without authority from Rep. Act. No. 997 and is thus void. Consequently, the Regional Office of the Department of Labor did not have the jurisdiction to adjudicate the claim. On the jurisdiction of the Hearing Officer: As a direct consequence of the declaration that Section 25 of Reorganization Plan No. 20-A is null and void, the Hearing Officer, Cedar V. Pastor, acted without jurisdiction in rendering judgment on the claim of Vicente Carin and his companions. The CFI of Cebu erred in upholding the constitutionality of the said provision and in denying the petition for Certiorari and Prohibition. The Supreme Court, in setting aside the CFI's decision, effectively declared that the Regional Office had no jurisdiction over the case.
Main Doctrine
Reorganization Plan No. 20-A, particularly Section 25 thereof, which grants to the regional offices original and exclusive jurisdiction over money claims of laborers, is null and void, said grant having been made without authority by Rep. Act. No. 997.