Case Digest (G.R. No. 58133)
Facts:
This case revolves around the seven petitioners: Mercedes Aguda, Aurea Pedrozo, Josephine Caraang, Lilia Durwin, Lourdes Larin, Lerna Villablanca, and Bernabe Llarenas, Jr. These individuals were employees of Adamson Ozanam Educational Institution, Inc., specifically working in its canteen from 1974 until their termination on June 2, 1980. Following their dismissal, the petitioners filed a complaint on June 27, 1980, with the National Capital Region of the Ministry of Labor in Intramuros, Manila, alleging illegal dismissal and additional claims regarding underpayment of their compensation, overtime pay, legal holiday pay, and premium pay for holidays. They cited violations of several Presidential Decrees (Nos. 525, 1123, 928, and 1389) related to labor rights. This complaint was registered under docket number NCR-S11 63655’80 or as case number AB-7-7490-80, and it was still pending a decision at the time of this case's proceedings.
Furthermore, on July 2, 1980, simultaneousl
Case Digest (G.R. No. 58133)
Facts:
- The petitioners—Mercedes Aguda, Aurea Pedrozo, Josephine Caraang, Lilia Durwin, Lourdes Larin, Lerna Villablanca, and Bernabe Llarenas, Jr.—were employed at the canteen of Adamson Ozanam Educational Institution, Inc.
- They were abruptly dismissed from their employment on June 2, 1980, after serving from 1974 up to that date.
Background of the Case
- On June 27, 1980, the petitioners filed a complaint with the National Capital Region of the Ministry of Labor in Intramuros, Manila, alleging illegal dismissal, underpayment of compensation, overtime pay, legal holiday pay, premium pay for holidays, and various labor law violations (including violations of Presidential Decrees Nos. 525, 1123, 928, and 1389).
- Simultaneously, on July 2, 1980, the petitioners initiated a separate civil action in the Court of First Instance of Manila seeking recovery of actual, moral, and exemplary damages amounting to P300,000.
Administrative and Civil Proceedings
- Adamson Ozanam Educational Institution, Inc. filed a motion to dismiss the civil complaint. The basis for dismissal centered on the contention that the petitioners’ claim for damages was exclusively within the jurisdiction of the Bureau of Labor Relations.
- The trial judge accordingly dismissed the complaint on July 22, 1980 for lack of jurisdiction.
- A motion for reconsideration was subsequently filed by the petitioners; however, due to the absence of a notice of hearing, the lower court treated it as a mere formality and issued subsequent orders on September 3 and September 24, 1980, effectively reiterating its position.
- With no further action taken by the petitioners, the lower court dismissed the case without prejudice on July 24, 1981.
Procedural Developments in the Civil Case
- On September 24, 1981, the petitioners filed a certiorari petition in the Supreme Court seeking reversal of the dismissal orders rendered by the lower court.
Certification for Review
Issue:
- Whether the complaint for actual, moral, and exemplary damages, arising from the alleged illegal dismissal of the petitioners, fell within the exclusive jurisdiction of the Labor Arbiters and the National Labor Relations Commission (NLRC) as mandated under labor law.
Jurisdictional Authority
- Whether Presidential Decree No. 1691, which took effect on May 1, 1980, properly restored and expanded the jurisdiction of the Labor Arbiters and the NLRC to include claims for moral and exemplary damages in employment disputes.
- Whether the trial court erred in asserting jurisdiction over a claim that had been designated, by the underlying law, to be adjudicated by specialized labor tribunals.
Interpretation of Relevant Labor Laws
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)