Victoria Biscuit Co. v. Benedicto
REITERATIONFacts
The Antecedents: Dionisio Bania filed a complaint against Victoria Biscuit Co., Inc. for overtime and separation pay with the Regional Office No. 3 of the Department of Labor. The Hearing Officer dismissed the complaint. Bania appealed to the Labor Standards Commission (LSC), which reversed the dismissal regarding overtime pay and awarded Bania P1,901.74. The LSC en banc affirmed the overtime pay but reduced the award to P904.87. Procedural History: Victoria Biscuit Co. appealed to the Court of First Instance (CFI) of Manila. Instead of filing an answer, Victoria Biscuit Co. filed a motion to dismiss, arguing lack of jurisdiction of the Regional Office and LSC, prescription, and release of claim. Bania manifested his conformity to the motion to dismiss, though not necessarily to the grounds. The CFI dismissed the case. Subsequently, the LSC Commissioner issued a writ of execution to enforce the LSC decision. Victoria Biscuit Co. filed a petition for certiorari with prohibition before the Supreme Court, arguing the CFI dismissal set aside the LSC decision and that the LSC lacked jurisdiction. The Petition: Victoria Biscuit Co. sought to annul the LSC decision and enjoin its execution, alleging that the CFI dismissal of its appeal had the effect of setting aside the LSC decision and that the LSC acted without or in excess of jurisdiction.
Issue(s)
Whether the dismissal of Civil Case No. 43863 by the Court of First Instance had the effect of reviving the decision of the Labor Standards Commission. Whether the decision of the Labor Standards Commission requiring Victoria Biscuit Co., Inc. to pay overtime pay to Dionisio Bania can be enforced.
Ruling
The Supreme Court reversed the judgment of the Court of First Instance, granted the petition for certiorari, declared the decision of the Labor Standards Commission null and void and of no effect, and enjoined its enforcement.
Ratio Decidendi
On the effect of the dismissal of Civil Case No. 43863: The Court held that the dismissal of the appeal by the Court of First Instance, upon motion of Victoria Biscuit Co., Inc., had the effect of withdrawing its appeal. The conformity of respondent Bania to the motion to dismiss was of no effect, as the dismissal was based on the grounds presented by the petitioner, primarily the lack of jurisdiction of the Regional Office and the Labor Standards Commission. Therefore, the dismissal of the appeal did not revive the decision of the Labor Standards Commission. On the enforceability of the Labor Standards Commission decision: The Court reiterated its ruling in a long line of decisions, including Corominas vs. Labor Standards Commission and Vicente Tan vs. Belen de Leon, that the Regional Office and the Labor Standards Commission were absolutely without jurisdiction over money claims like the one filed by Bania. Since the Labor Standards Commission had no jurisdiction over the subject matter, it also had no power to issue a writ of execution for the enforcement of its decision. The consent of the parties to a judgment rendered by a body without jurisdiction does not confer jurisdiction, as jurisdiction is conferred by law and not by the agreement of the parties. Consequently, the decision of the Labor Standards Commission was null and void and could not be enforced.
Main Doctrine
A decision rendered by a body without jurisdiction is null and void and cannot be enforced, even if the parties subsequently agree to its dismissal without prejudice to its grounds, as jurisdiction is conferred by law and cannot be acquired by consent.