Lumanta v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioners, fifty-four retrenched employees of Food Terminal, Inc. (FTI), filed a complaint against their employer for unpaid retrenchment or separation pay, underpayment of wages, and non-payment of emergency cost of living allowances (ECOLA). FTI, a government-owned and controlled corporation, argued that its employees are governed by the Civil Service Law, placing such claims under the jurisdiction of the Civil Service Commission, not the Department of Labor and Employment (DOLE). Procedural History: The complaint was initially filed with the DOLE. FTI moved to dismiss the complaint, asserting lack of jurisdiction. The Labor Arbiter granted the motion, dismissing the case for lack of jurisdiction, holding that it was governed by the Civil Service Law. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision on appeal. This resolution stems from a Petition for Certiorari filed by the employees seeking to annul the NLRC's decision. The Petition: The petitioners filed a Petition for Certiorari with the Supreme Court, arguing that the NLRC acted without or in excess of its jurisdiction. The core issue presented is whether a labor law claim against a government-owned and controlled corporation without an original charter falls under the jurisdiction of the DOLE. Petitioners contend that under the 1987 Constitution, FTI, not being chartered by special law, is excluded from the Civil Service, and thus their employment is governed by the Labor Code, making the DOLE the proper venue.
Issue(s)
Whether the National Labor Relations Commission (NLRC) acted without or in excess of jurisdiction in dismissing the petitioners' complaint, considering the nature of Food Terminal, Inc. (FTI) as a government-owned and controlled corporation (GOCC). Whether a labor law claim against a government-owned and controlled corporation (GOCC) falls within the jurisdiction of the Department of Labor and Employment (DOLE), and the relevance of the GOCC's charter in determining jurisdiction.
Ruling
The Petition for Certiorari is GRANTED. The Decision of the Labor Arbiter dated 31 August 1987 and the Decision of the NLRC dated 18 March 1988 are SET ASIDE. The case is REMANDED to the Labor Arbiter for further appropriate proceedings.
Ratio Decidendi
On the NLRC's jurisdiction regarding FTI: The Court held that the jurisdiction over labor disputes involving GOCCs depends on whether such GOCC has an "original charter." Under the 1987 Constitution, Article IX-B, Section 2(1), the civil service embraces all branches, subdivisions, instrumentalities, and agencies of the Government, including GOCCs "with original charter," referring to corporations chartered by special law. GOCCs without an original charter are governed by the Labor Code, with jurisdiction over their labor disputes falling under the DOLE. The Court found that FTI was organized under the general incorporation law and was not chartered by a special law, thus falling outside the scope of the civil service. Therefore, the Labor Arbiter and the NLRC erred in dismissing the petitioners' complaint for lack of jurisdiction, and the NLRC acted without or in excess of its jurisdiction in affirming the dismissal. The case was remanded to the Labor Arbiter for further proceedings. On the jurisdiction of the DOLE over labor claims against GOCCs and the relevance of the charter: The terms and conditions of employment of petitioners with FTI are governed by the Labor Code, and the dispute arising therefrom falls within the jurisdiction of the DOLE. The ruling in National Housing Authority v. Juco, which held that employees of GOCCs are governed by civil service law, was decided under the 1973 Constitution. The 1987 Constitution introduced a significant change by adding the phrase "with original charter." Therefore, the Juco ruling is no longer controlling in cases involving GOCCs without original charters under the present Constitution. The proper forum for the labor dispute was the DOLE, and the governing law was the Labor Code, not the Civil Service Rules and Regulations.
Main Doctrine
Government-owned and controlled corporations without an original charter are covered by the Labor Code, and disputes arising from their employment relationships fall under the jurisdiction of the Department of Labor and Employment, not the Civil Service Commission.