Cabrera v. National Service Corporation
REITERATIONFacts
1. The Antecedents: The petitioners, Teofilo Cabrera, Fausto Baclig, and Alfredo Agulan, were dismissed from their employment with the National Service Corporation (NASECO). They filed a complaint for illegal dismissal with the Ministry of Labor and Employment on September 17, 1980. The Labor Arbiter ruled in their favor, ordering reinstatement without loss of seniority rights and payment of two years' back wages and other benefits. 2. Procedural History: The First Division of the National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision on December 9, 1985. After the petitioners moved for a writ of execution, NASECO opposed, claiming it had not received a copy of the decision. This opposition was rejected, and the writ was granted. NASECO's subsequent motion for reconsideration was denied, leading to an appeal to the NLRC. The Third Division of the NLRC, however, declared itself without jurisdiction and dismissed the case on August 18, 1987, citing the ruling in National Housing Authority v. Juco. 3. The Petition: The petitioners seek review of the NLRC's dismissal order. They argue that the NLRC erred in finding itself without jurisdiction. The Supreme Court notes that while the petition does not explicitly allege grave abuse of discretion as required by Rule 65, it will overlook this procedural flaw due to the jurisdictional issue and the interest of substantial justice. The Court relies on the subsequent ruling in National Service Corporation v. NLRC, which overturned NHA v. Juco, holding that NASECO, as a government-owned or controlled corporation without an original charter, falls under the jurisdiction of the NLRC and its employees are governed by the Labor Code, not Civil Service rules.
Issue(s)
Whether the National Service Corporation (NASECO) is covered by the Labor Code or by Civil Service rules and regulations. Whether the National Labor Relations Commission (NLRC) has jurisdiction over the complaint for illegal dismissal filed by the petitioners. Whether NASECO is estopped from challenging the jurisdiction of the NLRC.
Ruling
The Supreme Court reversed and set aside the order of the NLRC dated August 18, 1987. The decision of the Labor Arbiter dated September 30, 1983, as affirmed by the NLRC on December 9, 1985, and his order dated April 4, 1986, were reinstated.
Ratio Decidendi
On whether NASECO is covered by the Labor Code or Civil Service rules: The Court held that the respondent NLRC erred in dismissing the petitioners' complaint for lack of jurisdiction. The ruling in National Housing Corporation v. Juco was overturned by the subsequent decision in National Service Corporation v. NLRC. The latter case clarified that only government-owned or controlled corporations with original charters are covered by the Civil Service. NASECO, having been organized under the Corporation Law and not by virtue of a special legislative charter, its relations with its personnel are governed by the Labor Code. Therefore, the NLRC has jurisdiction over the case. The Court applied the doctrine announced in National Service Corporation v. NLRC, which was decided under the 1987 Constitution. The 1987 Constitution, specifically Article IX-B, Section 2(1), provides that the Civil Service embraces government-owned or controlled corporations with original charters. Since NASECO does not have an original charter, it falls outside the scope of the Civil Service. On the jurisdiction of the NLRC over the complaint: Based on the above reasoning, the NLRC has jurisdiction over the complaint for illegal dismissal filed by the petitioners. On estoppel: The Court found that NASECO is estopped from challenging the jurisdiction of the NLRC. NASECO had accepted the jurisdiction of the labor authorities throughout the progress of the case until 1987, when it appealed the order of the Labor Arbiter for the issuance of a writ of execution. This prolonged acceptance of jurisdiction, coupled with its own assertion to the Merit System Board that the case was cognizable by labor authorities, operates against NASECO based on a long line of decisions.
Main Doctrine
Government-owned or controlled corporations without original charters are governed by the Labor Code and fall under the jurisdiction of the National Labor Relations Commission, not the Civil Service.