Tandayag v. Magsaysay Maritime Corporation
REITERATIONFacts
The Antecedents: Benjie Y. Tandayag (Tandayag), a Filipino seafarer, was hired as a laundry steward. While onboard, he experienced severe knee pain, was medically repatriated, and diagnosed with septic arthritis. Independent medical experts certified that he sustained a work-related injury rendering him permanently disabled and unfit for sea duties. Tandayag demanded disability benefits from his employers, Magsaysay Maritime Corporation and Princess Cruise Lines, Ltd., which were denied. Procedural History: Tandayag filed a complaint for total and permanent disability benefits, damages, and attorney's fees with the National Conciliation and Mediation Board, which referred the case to the Office of the Panel of Voluntary Arbitrators (Panel). The Panel ruled in favor of Tandayag. Upon appeal, the Court of Appeals annulled the Panel's decision, holding that the Panel lacked jurisdiction and that the labor arbiters had exclusive jurisdiction over the claim. The Petition: Tandayag filed a Petition for Review with the Supreme Court, arguing that the Panel had jurisdiction based on a submission agreement executed by the parties, as provided under Rule IV of the Revised Procedural Guidelines in the Conduct of Voluntary Arbitration Proceedings. He contended that the absence of a collective bargaining agreement did not divest the voluntary arbitrators of jurisdiction when a submission agreement existed.
Issue(s)
Whether the Office of the Panel of Voluntary Arbitrators had jurisdiction over Tandayag's complaint for permanent and total disability benefits, with claims for damages and attorney's fees, considering the provisions of Republic Act No. 8042, as amended by Republic Act No. 10022, and the POEA-SEC. Whether a submission agreement is sufficient to confer jurisdiction upon a voluntary arbitrator despite a consistent objection from the opposing party, and whether such objection prevents the submission agreement from constituting a waiver of the right to question jurisdiction.
Ruling
The petition is denied. The Court of Appeals did not err in dismissing petitioner's complaint for lack of jurisdiction. The August 20, 2020 Decision and March 23, 2021 Resolution of the Court of Appeals, Manila, are affirmed.
Ratio Decidendi
On Issue 1: The Court affirmed the Court of Appeals' ruling that the Office of the Panel of Voluntary Arbitrators lacked jurisdiction over Tandayag's complaint. While voluntary arbitrators have jurisdiction over disputes arising from collective bargaining agreements or company personnel policies, or other labor disputes upon agreement of the parties, this is distinct from claims for damages by overseas Filipino workers (OFWs). Section 10 of Republic Act No. 8042, as amended by Republic Act No. 10022, vests labor arbiters with original and exclusive jurisdiction over such claims, including damages. The Court clarified that while Section 29 of the POEA-SEC allows parties not covered by a CBA to choose between the NLRC (labor arbiters) or voluntary arbitrators, this choice must be mutual. On Issue 2: The Court held that a submission agreement does not automatically confer jurisdiction upon a voluntary arbitrator if one party consistently objects to it. While Article 262 of the Labor Code allows voluntary arbitrators to hear other labor disputes upon agreement of the parties, and Rule IV of the Revised Guidelines requires a submission agreement, this does not override the fundamental principle that jurisdiction is conferred by law and can be lost or not properly acquired if a party timely and consistently objects. The respondents' consistent objection to the Panel's jurisdiction from the outset, even including it as an issue for the Panel's resolution, prevented the submission agreement from constituting a waiver of their right to question jurisdiction. Therefore, the Panel erred in holding that the submission agreement waived the objection to its lack of jurisdiction, especially when its own jurisdiction was expressly submitted for resolution. The consistent objection by the respondents to the voluntary arbitrator's jurisdiction meant that the option to submit to voluntary arbitration was not validly exercised by both parties.
Main Doctrine
The jurisdiction over money claims of overseas Filipino workers (OFWs) generally lies with labor arbiters under Republic Act No. 8042, as amended. While voluntary arbitrators have jurisdiction over disputes arising from collective bargaining agreements or company personnel policies, or other labor disputes upon agreement of the parties, this jurisdiction is not absolute. If an OFW's claim involves damages and is filed with a voluntary arbitrator, but the employer consistently objects to the voluntary arbitrator's jurisdiction and asserts the labor arbiter's authority, the objection must be respected, and the case should be remanded to the labor arbiter. A submission agreement does not automatically confer jurisdiction if one party timely and consistently objects to it.