Ellao v. Batangas I Electric Cooperative
REITERATIONFacts
The Antecedents: Batangas I Electric Cooperative, Inc. (BATELEC I), an electric cooperative organized under Presidential Decree No. 269, engaged in power distribution in Batangas, employed Demetrio Ellao (Ellao) as its General Manager starting June 1, 2006. Prior to this, Ellao had been with BATELEC I since January 4, 1982. On February 12, 2009, a complaint was filed against Ellao, alleging irregularities in his performance as General Manager. A fact-finding body was formed, and Ellao was placed under preventive suspension. Despite submitting an explanation, the fact-finding body recommended his termination. On March 13, 2009, BATELEC I's Board of Directors passed a resolution terminating Ellao's employment based on gross and habitual neglect of duties, willful disobedience, and loss of trust and confidence. This termination was confirmed by the National Electrification Administration (NEA) on December 9, 2009. Procedural History: On February 23, 2011, Ellao filed a complaint for illegal dismissal and money claims before the Labor Arbiter, asserting that the charges were unsubstantiated and that he was denied procedural due process. BATELEC I moved to dismiss the complaint, arguing that the NEA, not the National Labor Relations Commission (NLRC), had jurisdiction. The Labor Arbiter asserted jurisdiction, found Ellao to have been illegally dismissed, and ordered his reinstatement with backwages, separation pay, moral damages, and attorney's fees. BATELEC I appealed to the NLRC, maintaining that the NEA or the Regional Trial Court (RTC), due to the intra-corporate nature of the dispute, had jurisdiction. The NLRC denied BATELEC I's appeal and partly granted Ellao's, modifying some monetary awards. BATELEC I then filed a petition for certiorari with the Court of Appeals (CA), reiterating its jurisdictional arguments. The CA granted the petition, reversing the NLRC's decision and dismissing Ellao's complaint without prejudice to seeking recourse in the appropriate forum, ruling that Ellao, as General Manager, was a corporate officer and his dismissal constituted an intra-corporate controversy falling under the jurisdiction of the SEC/RTC. The Petition: Through a Petition for Review on Certiorari under Rule 45 of the Rules of Court, petitioner Demetrio Ellao seeks to annul the CA's decision and resolution. Ellao contends that the CA erred in ruling that the RTC has jurisdiction based on its finding that he is a corporate officer and that the dispute is intra-corporate. The core issue presented to the Supreme Court is whether jurisdiction over Ellao's complaint for illegal dismissal belongs to the labor tribunals or the RTC. Ellao argues that his position as General Manager does not make him a corporate officer and that his dismissal is an employer-employee dispute cognizable by labor courts. The Supreme Court, however, affirmed the CA's ruling, holding that as the position of General Manager is expressly provided for in BATELEC I's By-laws, Ellao is considered a corporate officer, and his dismissal constitutes an intra-cooperative controversy within the jurisdiction of the RTC.
Issue(s)
Whether the labor tribunals have jurisdiction over the complaint for illegal dismissal filed by Ellao, who was the General Manager of BATELEC I, considering his position as a cooperative officer. Whether Ellao, as General Manager of BATELEC I, is a corporate officer whose dismissal constitutes an intra-cooperative controversy, thus falling outside the jurisdiction of labor tribunals.
Ruling
The petition is denied. The Decision dated April 26, 2013 and Resolution dated August 28, 2013 of the Court of Appeals in CA-G.R. SP No. 127281 are affirmed. The labor tribunals were without jurisdiction to take cognizance of Ellao's complaint, and their rulings therein are consequently void.
Ratio Decidendi
On the issue of jurisdiction over Ellao's complaint for illegal dismissal, considering his position as a cooperative officer: The Court held that complaints for illegal dismissal filed by a cooperative officer constitute an intra-cooperative controversy, and jurisdiction over such matters belongs to the regional trial courts (RTCs), not the labor tribunals. The Court clarified that BATELEC I, as an electric cooperative organized under Presidential Decree No. 269 (P.D. 269), possesses juridical personality and corporate powers akin to a corporation, even without SEC registration as a stock corporation. On the issue of whether Ellao's dismissal constitutes an intra-cooperative controversy: The Court emphasized that the termination disputes involving corporate officers are distinct from those of ordinary employees and fall under the jurisdiction of the SEC, now transferred to the RTCs by virtue of Republic Act No. 8799 (The Securities Regulation Code). The position of General Manager is expressly provided for in BATELEC I's By-laws, making it a cooperative office. Therefore, Ellao's dismissal as General Manager is an intra-cooperative controversy, not a labor dispute. The CA committed no reversible error in ordering the dismissal of Ellao's complaint without prejudice to his filing it in the proper forum, as the labor tribunals lacked jurisdiction, rendering their rulings void. The Court found no need to discuss the issue of illegal dismissal and monetary claims given the jurisdictional defect.
Main Doctrine
Complaints for illegal dismissal filed by a cooperative officer constitute an intra-cooperative controversy, jurisdiction over which belongs to the regional trial courts.