Title
Aguda vs. Vallejos
Case
G.R. No. 58133
Decision Date
Mar 26, 1982
Seven canteen employees dismissed in 1980 filed labor and civil cases; Supreme Court ruled damages claims fall under labor jurisdiction, affirming dismissal of civil suit.
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Case Digest (G.R. No. 58133)

Facts:

    Background of the Case

    • 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.

    Administrative and Civil Proceedings

    • 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.

    Procedural Developments in the Civil Case

    • 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.

    Certification for Review

    • 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.

Issue:

    Jurisdictional Authority

    • 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.

    Interpretation of Relevant Labor Laws

    • 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.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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