Juco v. National Housing Corporation
REITERATIONFacts
1. The Antecedents: Benjamin C. Juco was employed by the National Housing Corporation (NHC) as a project engineer from November 16, 1970, until his separation on May 14, 1975, due to alleged involvement in theft and/or malversation of public funds. This underlying dispute forms the basis of the subsequent legal proceedings concerning his dismissal. 2. Procedural History: Juco initially filed a complaint for illegal dismissal with the Department of Labor on March 25, 1977. This was dismissed by the Labor Arbiter for lack of jurisdiction on September 17, 1977. The National Labor Relations Commission (NLRC) reversed this decision on December 28, 1982. However, the Supreme Court, on January 17, 1985, granted NHC's petition, setting aside the NLRC's decision and reinstating the Labor Arbiter's dismissal for lack of jurisdiction. Subsequently, Juco filed a complaint with the Civil Service Commission on January 6, 1989, which was also dismissed for lack of jurisdiction on April 11, 1989. On April 28, 1989, Juco filed another complaint for illegal dismissal with the NLRC, which, on May 21, 1990, ruled in his favor, finding the dismissal illegal. NHC appealed this decision, and on March 14, 1991, the NLRC reversed the Labor Arbiter's ruling, again citing lack of jurisdiction. 3. The Petition: This case comes before the Supreme Court via a petition for certiorari seeking to set aside the NLRC's March 14, 1991 decision. The petitioner argues that the NLRC committed grave abuse of discretion in holding that he is not governed by the Labor Code. The core of the petition revolves around the interpretation of constitutional provisions and relevant jurisprudence regarding the jurisdiction over employees of government-owned and controlled corporations, specifically whether NHC, organized under the Corporation Law, falls under the Civil Service Law or the Labor Code, particularly in light of the 1987 Constitution.
Issue(s)
Whether the National Labor Relations Commission (NLRC) has jurisdiction over illegal dismissal cases involving employees of the National Housing Corporation (NHC). Whether the petitioner's complaint for illegal dismissal is barred by prescription.
Ruling
The petition is GRANTED. The decision of the NLRC dated March 14, 1991, is REVERSED, and the Decision of the Labor Arbiter dated May 21, 1990, is REINSTATED.
Ratio Decidendi
On the jurisdiction of the NLRC over NHC employees: The Court held that the NLRC did not commit grave abuse of discretion in taking cognizance of the illegal dismissal complaint. Under the 1987 Constitution, the civil service embraces only government-owned or controlled corporations (GOCCs) with original charters. Corporations organized under the general Corporation Code, like the NHC, are not covered by the Civil Service Law. Therefore, their employees are governed by the Labor Code and fall under the jurisdiction of the NLRC for labor disputes. The Court reiterated its ruling in National Service Corporation (NASECO) v. National Labor Relations Commission and Trade Union of the Philippines and Allied Services (TUPAS) v. National Housing Corporation, clarifying that the phrase "with original charter" in Article IX-B, Section 2(1) of the 1987 Constitution distinguishes GOCCs chartered by special law from those organized under the Corporation Law. Since NHC was incorporated under Act 1459 (the former corporation law), its personnel relations are governed by the Labor Code, placing it within the NLRC's jurisdiction. The NLRC erred in dismissing the petitioner's complaint for lack of jurisdiction based on the premise that NHC employees are governed by the Civil Service Law. On the issue of prescription: Although the NLRC reversed the Labor Arbiter's decision on jurisdictional grounds, the Labor Arbiter had previously ruled that the complaint was not barred by prescription. The Labor Arbiter reasoned that the reglementary period should be reckoned from the date of receipt of the CSC's dismissal order on April 11, 1989, and that the period was suspended due to the filing of the complaint with the CSC and the subsequent Supreme Court ruling enjoining the petitioner to go to the CSC. The Court, by reinstating the Labor Arbiter's decision, implicitly affirmed the finding that the complaint was not barred by prescription.
Main Doctrine
Government-owned or controlled corporations (GOCCs) organized under the Corporation Code, and not under an original charter, are covered by the Labor Code, and thus fall under the jurisdiction of the National Labor Relations Commission (NLRC) for labor disputes, including illegal dismissal cases.