Aboitiz Shipping Corp. v. Dela Serna
REITERATIONFacts
The Antecedents: The underlying dispute concerns alleged underpayments of daily allowances to employees of Aboitiz Shipping Corporation. Specifically, the employees claimed a deficiency of P2.00 per day from February 16, 1982, to February 15, 1985, and continuing thereafter until compliance. The aggregate amount of these claims was P1,350,828.00. Procedural History: The employees filed their claims with the Department of Labor and Employment (DOLE). The Regional Director issued an order on October 13, 1988, directing Aboitiz Shipping Corporation to pay the aggregate amount of P1,350,828.00 and to continue paying the deficiency. This order was affirmed by the Undersecretary of Labor and Employment on February 9, 1989, with a modification excluding one complainant from the money award. Aboitiz Shipping Corporation then filed a petition with the Supreme Court. The Petition: Aboitiz Shipping Corporation filed a motion for reconsideration of the Supreme Court's decision dated April 25, 1990. The primary contention was that the Regional Director lacked jurisdiction over the case because the aggregate amount of the claims exceeded P5,000.00, arguing it should have been referred to a Labor Arbiter. Petitioner also argued that the case fell under the exception clause of Article 128(b) of the Labor Code, divesting the Regional Director of visitorial and enforcement powers. The Supreme Court, referencing its ruling in Servando's Incorporated vs. the Secretary of Labor and Employment, denied the motion, holding that jurisdiction over claims exceeding P5,000.00 per employee rests with the Labor Arbiter, and that the exception clause in Article 128(b) was not applicable as the issues were verifiable in the normal course of inspection.
Issue(s)
Whether the Regional Director has jurisdiction over employees' money claims where the aggregate amount exceeds P5,000.00 for each employee. Whether the "exception clause" under Article 128(b) of the Labor Code applies to divest the Regional Director of jurisdiction over claims not exceeding P5,000.00 for each employee. Whether the findings of fact of the respondent public officials were supported by substantial evidence.
Ruling
The motion for reconsideration is denied. The Court reiterated that jurisdiction over employees' money claims exceeding P5,000.00 for each employee is vested in the Labor Arbiter. The exception clause under Article 128(b) was found not applicable as the issues raised were verifiable in the normal course of inspection. The factual findings of labor officials were affirmed as being supported by substantial evidence.
Ratio Decidendi
On the jurisdiction over money claims exceeding P5,000.00: The Court reiterated its ruling in Servando's Incorporated vs. the Secretary of Labor and Employment. It held that the original and exclusive jurisdiction to hear and decide employees' money claims arising from employer-employee relations, where the aggregate amount exceeds P5,000.00 for each employee, is vested in the Labor Arbiter, pursuant to Article 217(a)(6) of the Labor Code, as amended. This is further confirmed by Article 129 of the Labor Code, as amended, which excludes from the Regional Director's jurisdiction claims exceeding P5,000.00 for each employee. On the applicability of the "exception clause" under Article 128(b): The Court clarified that for the exception clause in Article 128(b) to apply, three elements must concur: (a) the employer must contest the findings of the labor regulation officer and raise issues thereon; (b) there must be a need to examine evidentiary matters to resolve these issues; and (c) such matters must not be verifiable in the normal course of inspection. In the present case, the Court found no justification for applying this exception, as the issues were resolved by an examination of evidentiary matters verifiable in the ordinary course of inspection, citing SSK Parts Corporation vs. Camas. Therefore, the Regional Director retained jurisdiction. On the substantiality of evidence: The Court disagreed with the petitioner's contention that the findings of fact of the respondent public officials were not based on substantial evidence. It found the questioned orders to be supported by substantial evidence. The Court reiterated the general rule that factual findings of labor officials are conclusive and binding on the Supreme Court when supported by substantial evidence.
Main Doctrine
The jurisdiction over employees' money claims arising from employer-employee relations exceeding P5,000.00 for each employee is vested in the Labor Arbiter, not the Regional Director. The exception clause under Article 128(b) of the Labor Code, which allows the Regional Director to exercise visitorial and enforcement powers despite the existence of an employer-employee relationship, requires the concurrence of three elements: (a) the employer contests the findings and raises issues; (b) evidentiary matters need examination to resolve these issues; and (c) such matters are not verifiable in the normal course of inspection.