Hawaiian-Philippine Company v. Gulmatico
REITERATIONFacts
The Antecedents: The National Federation of Sugar Workers-Food and General Trades (NFSW-FGT) filed a case against Hawaiian-Philippine Company (petitioner) for claims under Republic Act 809 (The Sugar Act of 1952), alleging that sugar farm workers within petitioner's milling district had not received benefits due them under the law. Section 9 of R.A. 809 mandates that 60% of the increase in participation granted to planters shall be divided between planters and laborers, with the laborers' share distributed under the supervision of the Department of Labor. Procedural History: Petitioner filed a Motion to Dismiss, asserting lack of jurisdiction and cause of action, arguing no employer-employee relationship existed between it and the farm workers. Respondent union opposed this. Petitioner later amended its complaint, impleading additional complainants and respondents, including planters. One respondent planter also filed a motion to dismiss and to include necessary parties. Public respondent Labor Arbiter Reynaldo J. Gulmatico denied petitioner's motion to dismiss. The Petition: Petitioner seeks certiorari and prohibition to annul the Labor Arbiter's order, reasserting that the Labor Arbiter lacks jurisdiction and that the union has no cause of action against it.
Issue(s)
Whether the Labor Arbiter has jurisdiction to hear and decide the case against petitioner. Whether the respondent union and/or the farm workers have a cause of action against petitioner.
Ruling
The petition is GRANTED. Public respondent Reynaldo J. Gulmatico is ORDERED to DISMISS RAB VI Case No. 06-07-10256-89 with respect to herein petitioner Hawaiian-Philippine Company and to PROCEED WITH DISPATCH in resolving the said case.
Ratio Decidendi
On the issue of jurisdiction: The Court held that the Labor Arbiter's jurisdiction is limited to cases arising from or in connection with an employer-employee relationship, as enumerated in Article 217 of the Labor Code. In this case, there is no employer-employee relationship between the petitioner milling company and the respondent sugar farm workers. The Solicitor General correctly noted that public respondent did not dispute this fact. Absent the jurisdictional requisite of an employer-employee relationship, the Labor Arbiter is without jurisdiction to hear and decide the case concerning the petitioner. The ruling in San Miguel Corporation vs. NLRC and Federation of Free Farmers vs. Court of Appeals supports the contention that all cases under the Labor Arbiter's jurisdiction must stem from an employer-employee relationship. On the issue of cause of action: The Court ruled that the respondent union and/or its members-workers have no cause of action against the petitioner. To establish a cause of action, a claimant must show a legal right and a correlative duty on the respondent, which the latter violated. Section 9 of R.A. 809 and Section 1 of LOI 845 clearly indicate that the payment of the workers' share is a liability of the planters-employers, not the milling company. The Court reiterated its ruling in Federation of Free Farmers, stating that the Sugar Act does not create any relationship between the laborers of the planters and the centrals, nor does it make the central an insurer of the planters' obligation to pay their laborers. Once the central distributes the planters' share, it is out of the picture. The petitioner has fulfilled its part by distributing the planters' shares, and thus has no further obligation regarding the subsequent distribution of the workers' share.
Main Doctrine
A Labor Arbiter has no jurisdiction over a case involving claims under Republic Act 809 if no employer-employee relationship exists between the milling company and the sugar farm workers, as the liability for the workers' share rests solely with the planters.