Zamboanga City Water District v. Buat
REITERATIONFacts
1. The Antecedents: The Zamboanga City Water District (ZCWD), a government-owned and controlled corporation, faced a strike in March 1987 initiated by its employees, who are the private respondents in this case. Following the strike, ZCWD separated these employees from their employment. ZCWD subsequently filed a complaint to declare the strike illegal, while the employees' union filed a separate complaint for illegal dismissal and unpaid wages. 2. Procedural History: The two labor cases were consolidated, and the Executive Labor Arbiter declared both the strike and the dismissals illegal, ordering reinstatement without back wages. The National Labor Relations Commission (NLRC) affirmed this decision, modifying it to suspend the strike leader for six months without pay. ZCWD appealed to the Supreme Court, which initially issued a restraining order but later dismissed the petition, affirming the NLRC decision. After ZCWD reinstated most employees, private respondents sought immediate reinstatement of the suspended leader and back wages. The Executive Labor Arbiter denied this, but the NLRC, on appeal, ordered the reinstatement of the strike leader and granted back wages to all private respondents for specific periods, including the duration of the Supreme Court's restraining order. The NLRC denied ZCWD's motion for reconsideration. 3. The Petition: ZCWD filed this petition for certiorari under Rule 65 of the Revised Rules of Court, challenging the NLRC's resolutions. ZCWD argues that the NLRC lacked jurisdiction over labor disputes involving government-owned corporations, which should fall under the Civil Service Commission. Additionally, ZCWD contends that the NLRC gravely abused its discretion by ordering the payment of salaries to private respondents during the period when this Court's restraining order was in effect.
Issue(s)
Whether the NLRC has jurisdiction over labor disputes involving a government-owned and controlled corporation, considering the application of Civil Service Law and Rules. Whether petitioner is estopped from assailing the NLRC's jurisdiction, given their prior actions before the labor arbiter and NLRC. Whether the NLRC committed grave abuse of discretion in ordering the payment of salaries during the effectivity of this Court's temporary restraining order, and the implications of Article 223 of the Labor Code.
Ruling
The petition is DISMISSED. The NLRC's resolutions are affirmed.
Ratio Decidendi
On the jurisdiction of the NLRC: While government-owned and controlled corporations (GOCCs) are generally governed by Civil Service Law and Rules, implying jurisdiction lies with the Civil Service Commission, the Court found that petitioner ZCWD had voluntarily invoked the jurisdiction of the NLRC by filing a complaint and seeking affirmative relief in the labor arbiter and NLRC. Therefore, petitioner is estopped from later assailing the jurisdiction of the NLRC. On the issue of estoppel: It is not fair for a party who has voluntarily invoked the jurisdiction of a tribunal to secure an affirmative relief therefrom, to afterwards repudiate and deny that very same jurisdiction to escape a penalty. Petitioner's active participation in the proceedings before the Executive Labor Arbiter and the NLRC, including filing its own complaint, demonstrated a clear waiver of any objection to the jurisdiction of these bodies. This conduct precluded ZCWD from raising the issue of jurisdiction for the first time in the Supreme Court. On the payment of salaries during the restraining order: The decision of the Labor Arbiter reinstating a dismissed employee is immediately executory, even pending appeal, as provided by Article 223 of the Labor Code, as amended by R.A. No. 6715. The employer can either reinstate the employee or place them on payroll. The issuance of a temporary restraining order (TRO) by the Supreme Court did not nullify the rights of private respondents to reinstatement and wages during its effectivity but merely suspended the implementation thereof pending the Court's final determination. Since the Supreme Court ultimately affirmed the NLRC decision, private respondents are entitled to wages accruing during the TRO period. The NLRC's computation of back wages, including the period of the TRO, was therefore correct.
Main Doctrine
A government-owned and controlled corporation, even if it has an original charter, is subject to Civil Service Law and Rules. However, a party that voluntarily invokes the jurisdiction of a tribunal and seeks affirmative relief therefrom is estopped from later denying that jurisdiction. Furthermore, decisions of the Labor Arbiter ordering reinstatement are immediately executory, even pending appeal, and this mandate is not stayed by a temporary restraining order, which only suspends implementation pending resolution.