Camporedondo v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: Petitioner Baltazar G. Camporedondo was employed with the Philippine National Red Cross (PNRC) from 1980 until his early retirement on December 15, 1995. He was the administrator of the Surigao del Norte Chapter. In July 1995, a field auditor found petitioner short in the sum of P109,000.00. On November 21, 1995, the PNRC Secretary General required petitioner to restitute P135,927.78 representing cash shortage, technical shortage, and unremitted collections within seventy-two hours. Petitioner applied for early retirement and requested a re-audit by an independent auditor, which was denied. Procedural History: On May 28, 1996, petitioner filed a complaint for illegal dismissal, damages, and underpayment of wages with the National Labor Relations Commission (NLRC). The PNRC filed a motion to dismiss, arguing lack of jurisdiction because the PNRC is a government corporation whose employees are members of the Government Service Insurance System (GSIS) and covered by the Civil Service Law. The Labor Arbiter dismissed the complaint for lack of jurisdiction, finding the PNRC to be a government corporation with an original charter under Republic Act No. 95. Petitioner's motion for reconsideration was denied. The NLRC dismissed petitioner's appeal, affirming the Labor Arbiter's decision. The Petition: Petitioner filed a petition for certiorari with the Supreme Court, questioning the NLRC's dismissal of his appeal and the Labor Arbiter's ruling on jurisdiction.
Issue(s)
Whether the Philippine National Red Cross (PNRC) is a government-owned and controlled corporation subject to the jurisdiction of labor tribunals; and whether the NLRC committed grave abuse of discretion in dismissing the petitioner's complaint for illegal dismissal.
Ruling
The petition is dismissed. The ruling of the National Labor Relations Commission is affirmed.
Ratio Decidendi
On the issue of jurisdiction over the PNRC and the NLRC's actions: The Supreme Court affirmed the ruling of the NLRC and the Labor Arbiter that the Philippine National Red Cross (PNRC) is a government-owned and controlled corporation. The Court reiterated the test for determining whether a corporation is government-owned or controlled: whether it was created by its own charter for the exercise of a public function, or by incorporation under the general corporation law. Corporations with special charters are considered government corporations, and their employees fall under the jurisdiction of the Civil Service Commission and are compulsory members of the Government Service Insurance System (GSIS). The PNRC was created by Republic Act No. 95, its original charter, thus establishing it as a government corporation. The Court clarified that amendments to its charter, such as granting it authority to secure loans or exemptions, did not convert it into a private organization. The petitioner's employment with the PNRC meant he was covered by the Civil Service Law and GSIS, and thus, labor disputes concerning his employment were outside the jurisdiction of the NLRC. His application for early retirement under Presidential Decree No. 1146 or Republic Act No. 1616 further indicated his awareness of his status as a government employee. Therefore, the dismissal of his complaint for illegal dismissal by the labor tribunals for lack of jurisdiction was proper.
Main Doctrine
The Philippine National Red Cross (PNRC) is a government-owned and controlled corporation with an original charter under Republic Act No. 95, and therefore, its employees are under the jurisdiction of the Civil Service Commission and are compulsory members of the Government Service Insurance System, placing labor disputes concerning its employees outside the jurisdiction of labor tribunals.