Enjay v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: The Samahan ng Mga Manggagawa sa Hotel Inter-Continental Manila (the Union) filed claims for overtime pay, wage differentials, and service charges against Hotel Inter-Continental Manila (the Hotel) before the Court of Industrial Relations (CIR) in Case No. 3448-V. Subsequently, the Union filed an unfair labor practice charge against the Hotel for allegedly depriving its employees of their 1973 Christmas bonus due to union activities (Charge No. 5657). Procedural History: The Hotel filed motions to dismiss both the claims and the charge, arguing that the Union lacked the personality to represent its members in such matters and that the CIR had no jurisdiction under Presidential Decree No. 21, which vested original and exclusive jurisdiction over employee-employer disputes in the National Labor Relations Commission (NLRC). The CIR judges denied the motions to dismiss and subsequent motions for reconsideration, ruling that the orders were not appealable to the CIR en banc. The Petition: The Hotel filed a petition for review, treated as a special civil action for certiorari, seeking to set aside the CIR's orders and resolutions. The Hotel invoked Presidential Decree No. 21 and Letter of Instructions No. 191, which directed the CIR to transfer cases filed after October 14, 1972, to the Bureau of Labor Relations. The Union conceded that employer-employee relationship cases should have been brought before the NLRC but argued that the effectivity of the Labor Code on November 1, 1974, rendered the jurisdictional issue academic, as the Code abolished the CIR and the old NLRC. The Union prayed for the transfer of the cases to the new NLRC.
Issue(s)
Whether the Court of Industrial Relations (CIR) had jurisdiction over Case No. 3448-V. Whether the CIR erred in denying the Hotel's motion to dismiss.
Ruling
The petition for certiorari is meritorious. The CIR acted without jurisdiction in entertaining Case No. 3448-V, as its subject matter fell within the original and exclusive jurisdiction of the National Labor Relations Commission. The CIR erred in not granting the Hotel's motion to dismiss. The order dated February 20, 1974, and the resolution of July 29, 1974, being coram non judice, are set aside. Pursuant to Section 338 of the Labor Code, the Union's prayer that CIR Case No. 3448-V be transferred to the new National Labor Relations Commission is granted.
Ratio Decidendi
On Issue 1: The Court held that the CIR acted without jurisdiction in entertaining Case No. 3448-V. Presidential Decree No. 21, issued on October 24, 1972, conferred original and exclusive jurisdiction over all matters involving employee-employer relations, including disputes that may lead to strikes and lock-outs, upon the National Labor Relations Commission (NLRC). The claims for overtime pay, wage differentials, and service charges clearly fall within the ambit of employee-employer relations. Therefore, the CIR should have dismissed the case for lack of jurisdiction, as it was vested with jurisdiction only over cases filed prior to the effectivity of PD 21, or those not covered by its exclusive jurisdiction. The subsequent issuance of Letter of Instructions No. 191 further reinforced the transfer of cases filed after October 14, 1972, to the appropriate labor relations body. On Issue 2: The Court found that the CIR erred in denying the Hotel's motion to dismiss. The motion was grounded on the lack of jurisdiction of the CIR over the subject matter, which was vested in the NLRC by virtue of Presidential Decree No. 21. The principle that a court or tribunal without jurisdiction over the subject matter cannot validly act on a case is fundamental. The CIR's denial of the motion to dismiss, therefore, constituted a grave abuse of discretion amounting to lack of jurisdiction. The subsequent effectivity of the Labor Code, which abolished the CIR and the old NLRC, did not cure the initial jurisdictional defect but rather necessitated the transfer of the pending case to the new NLRC as provided by Article 338 of the Code.
Main Doctrine
The Court of Industrial Relations (CIR) acted without jurisdiction in entertaining cases that fell under the original and exclusive jurisdiction of the National Labor Relations Commission (NLRC) as established by Presidential Decree No. 21. The subsequent effectivity of the Labor Code, which abolished the CIR and the old NLRC, necessitated the transfer of all pending cases, including the one at bar, to the newly created NLRC for proper disposition.