Bengzon v. Deputy Minister of Labor
REITERATIONFacts
The Antecedents: Petitioner Lourdes E. Bengzon filed a complaint for illegal dismissal against respondent Sta. Ines-Melale Veneer & Plywood Corporation (Sta. Ines) and its Vice-President, Robert V. Hyde. The initial decision by the Labor Arbiter ordered Sta. Ines to pay separation pay and respondent Hyde to pay moral and exemplary damages. Petitioner appealed, seeking to hold Sta. Ines solidarily liable for damages, while Hyde challenged the Labor Arbiter's jurisdiction over him. Procedural History: The National Labor Relations Commission (NLRC) initially remanded the case due to improper service of summons on Hyde. Appeals by Sta. Ines to the Secretary of Labor and the Office of the President affirmed this resolution. Meanwhile, petitioner filed an amended complaint, which was consolidated with the original case. A subsequent Labor Arbiter decision ordered Sta. Ines and Hyde to pay jointly and severally. The NLRC modified this, ordering Sta. Ines to pay backwages, separation pay, and damages, but absolving Hyde. Sta. Ines appealed this decision to the Secretary of Labor, who affirmed the NLRC's decision but modified it by setting aside the award of damages, citing Presidential Decree No. 1367. The Petition: Petitioner seeks a writ of certiorari, arguing that the Deputy Minister of Labor gravely abused his discretion in disclaiming jurisdiction over the issue of damages. Petitioner contends that under Article 217 of the Labor Code, prior to its amendment by Presidential Decree No. 1367, Labor Arbiters had jurisdiction over such claims. The petition emphasizes that the relevant decisions were rendered before the promulgation of PD 1367 and that requiring a separate suit for damages in regular courts would sanction split jurisdiction, contrary to the orderly administration of justice.
Issue(s)
Whether the Deputy Minister of Labor gravely abused his discretion in disclaiming jurisdiction over the issue of moral and exemplary damages based on Presidential Decree No. 1367. Whether Presidential Decree No. 1367, which amended Article 217 of the Labor Code to exclude claims for damages from the jurisdiction of labor arbiters, has retroactive effect on cases pending prior to its promulgation.
Ruling
The petition for certiorari is granted. The respondent Deputy Minister of Labor is directed to decide the appeal on the question of moral and exemplary damages.
Ratio Decidendi
On the jurisdiction over damages prior to PD 1367: At the time the Labor Arbiter rendered the decision in the consolidated cases, the applicable law was Article 217 of the Labor Code. This provision granted labor arbiters exclusive jurisdiction over various cases arising from employer-employee relations, including money claims and "all other cases arising from employer-employee relation unless expressly excluded by this Code." The Court has previously interpreted these provisions broadly, as seen in Garcia v. Martinez, et al., ruling that claims for damages arising from unjustified dismissal fall within the exclusive jurisdiction of the National Labor Relations Commission (NLRC). The intent of the Labor Code was to expand the jurisdiction of labor tribunals to encompass all employer-employee relations, unlike the limited jurisdiction of the Court of Industrial Relations. Therefore, the Labor Arbiter and the NLRC possessed the necessary jurisdiction to hear and decide the petitioner's claim for moral and exemplary damages. On the retroactive application of PD 1367: The general rule is that where a court has already obtained and is exercising jurisdiction over a controversy, its jurisdiction to proceed to final determination is not affected by new legislation placing jurisdiction over such proceedings in another tribunal. An exception exists where the statute expressly provides or is construed to operate retroactively on pending actions. Presidential Decree No. 1367 was promulgated on May 1, 1978, after the Labor Arbiter's decision (November 18, 1977) and the NLRC's en banc decision (February 21, 1978) in the consolidated cases. The decree does not contain any provision indicating a retroactive application. To require the petitioner to file a separate suit for damages in the regular courts would sanction split jurisdiction, which is prejudicial to the orderly administration of justice. Thus, the jurisdiction acquired by the labor tribunals prior to the enactment of PD 1367 should be respected.
Main Doctrine
The jurisdiction of labor arbiters and the National Labor Relations Commission over claims for damages arising from employer-employee relations, as defined under Article 217 of the Labor Code prior to its amendment by Presidential Decree No. 1367, is exclusive. A subsequent amendment to the law divesting such jurisdiction will not affect cases already pending and decided by the labor tribunals.