Dela Cruz v. First Bukidnon Electric Cooperative
REITERATIONFacts
The Antecedents: Engr. Jose S. Dela Cruz (Dela Cruz) was employed by First Bukidnon Electric Cooperative, Inc. (FIBECO) and was promoted to General Manager in 2001. In 2007, an administrative complaint was filed against him for grave offenses, including nepotism, insubordination, misuse of FIBECO properties/funds, and gross incompetence. FIBECO's Board of Directors found him guilty and dismissed him from service. The National Electrification Administration (NEA) Board of Administrators confirmed this dismissal. Procedural History: Dela Cruz filed illegal dismissal cases, which were ultimately resolved by the Supreme Court in G.R. No. 229485, upholding the NEA's jurisdiction over the termination dispute and the finality of the NEA's dismissal resolution. While this dispute was pending, Dela Cruz reached compulsory retirement age in 2013. He applied for retirement benefits with FIBECO, which was denied. He pursued his claim before the Labor Arbiter (LA), who dismissed it for lack of jurisdiction. The National Labor Relations Commission (NLRC) reversed this, remanding the case to the LA. However, the LA again dismissed the claim, asserting NEA's exclusive jurisdiction. The NLRC subsequently reversed its earlier stance and ordered FIBECO to pay Dela Cruz's retirement benefits, stating its earlier resolution had become final and executory. FIBECO filed a petition for certiorari with the Court of Appeals (CA), arguing grave abuse of discretion by the NLRC. The CA upheld the labor tribunal's jurisdiction based on the finality of the NLRC ruling but deleted the award of retirement benefits, finding Dela Cruz ineligible due to his valid dismissal. The Petition: Dela Cruz filed a Petition for Review on Certiorari with the Supreme Court, challenging the CA's deletion of his retirement benefits. He argued that the CA erred in relying on the Supreme Court's ruling in G.R. No. 229485, as it only resolved the jurisdictional issue and not the merits of his dismissal. He also claimed to have remained employed until his retirement.
Issue(s)
Whether the Court of Appeals erred in upholding the labor tribunal's jurisdiction over Dela Cruz's claim for retirement benefits. Whether Dela Cruz is entitled to retirement benefits.
Ruling
The Petition for Review on Certiorari is DENIED. The Decision dated July 29, 2019, and the Resolution dated September 14, 2020, of the Court of Appeals-Cagayan de Oro City in CA-G.R. SP No. 08417-MIN are AFFIRMED as to the deletion of the award of retirement benefits.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court held that the National Electrification Administration (NEA) has primary and exclusive jurisdiction over administrative cases involving electric cooperative officers, including claims for retirement benefits. This jurisdiction is conferred by Presidential Decree (PD) No. 269, as amended by Republic Act (RA) No. 10531. The Court emphasized that jurisdiction is conferred by law and cannot be acquired through waiver, acquiescence, or estoppel, thus rectifying the CA's error in sustaining the labor tribunal's jurisdiction based solely on the finality of an earlier NLRC ruling. The NEA's supervisory and disciplinary powers, as outlined in Section 6 of RA No. 10531 and Section 7 of its Implementing Rules and Regulations, explicitly include adjudicating cases affecting electric cooperatives and their officers, such as the General Manager. The Court cited the case of National Electrification Administration v. Civil Service Commission to support the principle that incidental powers necessary for the effective exercise of conferred jurisdiction are included. Therefore, FIBECO's denial or inaction on Dela Cruz's claim should have been brought to the NEA, in accordance with the retirement policy. On the entitlement to retirement benefits: The Supreme Court affirmed the CA's deletion of the award of retirement benefits, holding that Dela Cruz is not entitled to them due to his valid dismissal from service. The validity of Dela Cruz's dismissal was already settled in G.R. No. 229485, which upheld the NEA's jurisdiction and the finality of NEA Resolution No. 79, dismissing him. This dismissal entails the forfeiture of his retirement benefits as provided by Section 3(a), Rule VII of the Rules of Procedure of the NEA on administrative cases. This rule explicitly states that the penalty of dismissal carries with it the forfeiture of retirement benefits, unless the decision provides otherwise. Since NEA Resolution No. 79 did not provide for his entitlement to retirement benefits despite the finding of guilt, the CA committed no reversible error in deleting the NLRC's award.
Main Doctrine
The National Electrification Administration (NEA) has primary and exclusive jurisdiction over administrative cases involving electric cooperative officers, including claims for retirement benefits, as conferred by Presidential Decree No. 269, as amended by Republic Act No. 10531. Dismissal from service due to grave offenses results in the forfeiture of retirement benefits, unless otherwise provided in the decision.