Philippine Overseas Drilling and Oil Development Corporation v. Ministry of Labor
REITERATIONFacts
The Antecedents: Private respondent Mariano M. Melendres, Jr. resigned as Chief Geologist of petitioner Philippine Overseas Drilling and Oil Development Corporation (PODOC) on August 29, 1979, effective one month thereafter. He had been employed since June 1969. On November 20, 1979, he inquired about his resignation and claimed separation pay and other benefits similar to those granted to other resigned employees. PODOC, without replying, filed an application for clearance to terminate his employment effective September 29, 1979, citing his resignation. Private respondent opposed this, charging unfair labor practice and undue discrimination for refusal to grant separation pay. Procedural History: The case was docketed as Case No. NCR-STF-12-7820-79 before the Ministry of Labor and Employment (MOLE), Regional Director Francisco L. Estrella. Despite an agreement to submit position papers, PODOC failed to do so. On August 7, 1980, Director Estrella issued an Order directing PODOC to pay private respondent P67,400.00 as termination benefit per company policy, finding that non-granting of such benefit would constitute unfair discrimination. PODOC received notice of this Order on August 13, 1980. On November 28, 1980, a writ of execution was issued. On December 10, 1980, PODOC filed a Motion for Reconsideration and/or Appeal. An indorsement on December 16, 1980, forwarded the record to the Minister of Labor, noting PODOC's appeal. On the same date, PODOC filed the instant petition for certiorari. The Petition: PODOC sought to nullify the MOLE Director's Order and writ of execution, arguing that the regular courts, not the MOLE, had jurisdiction, and that the Director erred in granting separation pay as private respondent voluntarily resigned and no company policy supported such a grant.
Issue(s)
Whether the Ministry of Labor and Employment had jurisdiction over the case. Whether the respondent Director acted with grave abuse of discretion in granting separation pay to the private respondent. Whether the petition was filed within a reasonable time.
Ruling
The petition is dismissed for lack of merit. The temporary restraining order is lifted and set aside.
Ratio Decidendi
On the issue of jurisdiction: The Court ruled that the respondent Director had jurisdiction over the case. The complaint filed by the private respondent alleged undue discrimination in the refusal to pay separation pay, clearly arising from an employer-employee relationship. At the time of the complaint's filing on December 18, 1979, the Labor Code vested original and exclusive authority over such disputes in the Bureau of Labor Relations and its regional offices. Presidential Decree No. 1691, which later vested exclusive jurisdiction over money claims and other cases arising from employer-employee relations in Labor Arbiters, did not divest the Regional Director of jurisdiction over this case, as it was already pending and exercising jurisdiction. Furthermore, the petitioner is barred by estoppel from raising the issue of jurisdiction, having failed to raise it before the MOLE and only doing so for the first time in the petition for certiorari, after actively participating in the proceedings. On the issue of grave abuse of discretion in granting separation pay: The Court held that the respondent Director did not act with grave abuse of discretion. Findings of administrative agencies with expertise are generally accorded respect and finality. The Director's finding that a company policy existed to grant separation benefits to similarly situated employees was supported by substantial evidence, including documents presented as Annexes 'D' through 'D-7' of the private respondent's position paper. This policy warranted the award of separation benefits, even for a voluntary resignation, consistent with basic principles of labor law and the employee's ten years of service. On the timeliness of the petition: The Court noted that the petition was filed on December 10, 1980, almost four months after PODOC received notice of the August 7, 1980 Order. While certiorari actions only require filing within a reasonable time, the Court found that the delay in this case was not reasonable, especially considering the issuance of a writ of execution prior to the filing of the petition.
Main Doctrine
A party is barred by estoppel from raising the issue of jurisdiction if it actively participated in the proceedings before the tribunal without raising such objection, and only assailed jurisdiction for the first time in a petition for certiorari before the Supreme Court.