Title
Cabrera vs. National Labor Relations Commission
Case
G.R. No. 83387
Decision Date
Jun 27, 1991
Workers dismissed by NASECO filed for illegal dismissal; Supreme Court ruled NLRC had jurisdiction, reinstating Labor Arbiter's decision, affirming NASECO as subject to Labor Code.
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Case Digest (G.R. No. 83387)

Facts:

1. Initial Complaint and Labor Arbiter's Decision:

  • Petitioners Teofilo Cabrera, Fausto Baclig, and Alfredo Agulan were dismissed by the National Service Corporation (NASECO).
  • They filed a complaint for illegal dismissal with the Ministry of Labor and Employment on September 17, 1980.
  • The Labor Arbiter ruled in favor of the petitioners, ordering their reinstatement without loss of seniority rights and payment of two years' back wages and other benefits.

2. NLRC's First Division Affirmation:

  • NASECO appealed the Labor Arbiter's decision to the First Division of the National Labor Relations Commission (NLRC).
  • On December 9, 1985, the NLRC affirmed the Labor Arbiter's decision.

3. Writ of Execution and NASECO's Opposition:

  • The petitioners moved for the issuance of a writ of execution.
  • NASECO opposed the writ, claiming it had not been furnished a copy of the decision.
  • The opposition was rejected, and the writ was granted.

4. NLRC's Third Division Dismissal:

  • NASECO appealed to the NLRC's Third Division, which dismissed the case on August 18, 1987.
  • The Third Division ruled that NASECO was not covered by the Labor Code but by Civil Service rules, citing the National Housing Authority (NHA) v. Juco case.

5. NASECO's Jurisdictional Argument:

  • NASECO argued that it was a government-owned or controlled corporation and thus subject to Civil Service rules.
  • However, in a previous case, NASECO's general manager had stated that it was a private corporation under the Corporation Law.

Issue:

  1. Jurisdiction: Whether the NLRC had jurisdiction over the petitioners' complaint, given NASECO's status as a government-owned or controlled corporation.
  2. Applicability of the 1987 Constitution: Whether the 1987 Constitution, which governs government-owned or controlled corporations without original charters, applies to NASECO.
  3. Estoppel: Whether NASECO is estopped from challenging the NLRC's jurisdiction after previously accepting it.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court ruled in favor of the petitioners, reinstating the Labor Arbiter's decision and affirming the NLRC's jurisdiction over NASECO. The Court emphasized the importance of the 1987 Constitution's provisions and the principle of estoppel in resolving jurisdictional disputes.


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