Akay Printing Press v. Minister of Labor and Employment
REITERATIONFacts
The Antecedents: Private respondents Nelson Olayta and Jose Polpol were employed as helpers by petitioner Akay Printing Press. In August 1978, petitioner issued a memorandum warning them about alleged negligence leading to the rejection of printed articles, stating that repetition might lead to termination. Private respondents refused to receive the memorandum, and consequently, were dismissed without MOLE clearance. Procedural History: Private respondents filed a complaint for illegal dismissal. The Regional Director of the Ministry of Labor and Employment (MOLE) conducted hearings and, after parties submitted position papers (only complainants complied), issued an order on July 31, 1979, finding the dismissal illegal and ordering reinstatement with backwages. Petitioner filed a motion for reconsideration, claiming abandonment, not dismissal. This was treated as an appeal and elevated to the MOLE. On May 25, 1981, the Deputy Minister affirmed the Regional Director's order. Petitioner then filed a motion for reconsideration assailing, for the first time, the jurisdiction of the Regional Director. This motion was denied. The Petition: Petitioner filed a petition for certiorari, assailing the orders of the Regional Director and Deputy Minister on two alternative grounds: (1) the Regional Director's order was void for lack of jurisdiction under Article 217 of the Labor Code, as amended by PD 1367, and (2) even if valid, the finding of dismissal was erroneous, as private respondents had abandoned their work.
Issue(s)
Whether the Regional Director had jurisdiction over the illegal dismissal complaint. Whether private respondents were illegally dismissed or had abandoned their work.
Ruling
The petition is dismissed. The backwages of private respondents shall be limited to the amount corresponding to three years.
Ratio Decidendi
On the issue of jurisdiction: The Court held that petitioner was estopped from questioning the jurisdiction of the Regional Director. Petitioner did not raise the issue of jurisdiction during the hearings or in its initial motion for reconsideration, instead arguing that private respondents abandoned their work. The challenge to jurisdiction was raised only in a subsequent motion for reconsideration after the case was elevated to the Ministry of Labor and Employment and an adverse decision was rendered. The Court reiterated the principle that a party cannot invoke the jurisdiction of a court or tribunal to secure affirmative relief and then repudiate that same jurisdiction after obtaining an unfavorable decision. This practice is not tolerated for reasons of public policy. Furthermore, after voluntarily submitting a cause and encountering an adverse decision on the merits, it is too late for the loser to question the jurisdiction or power of the tribunal. The Court cited several precedents establishing this principle of estoppel. On the issue of dismissal versus abandonment: The Court found that the findings of fact of quasi-judicial bodies, when supported by substantial evidence, are binding on the courts. The records showed that private respondents were dismissed on August 15, 1978, without investigation and prior MOLE clearance, after they refused to receive a warning memorandum. Petitioner's defense of abandonment was raised belatedly in its motion for reconsideration and was not given credence for lack of evidentiary support. Therefore, the finding of illegal dismissal was upheld.
Main Doctrine
A party who voluntarily submits a case for decision and encounters an adverse judgment is estopped from questioning the jurisdiction of the tribunal, especially when such challenge is raised for the first time only after an adverse decision on the merits has been rendered and affirmed.