Case Digest (G.R. No. 83387)
Facts:
The case involves Teofilo Cabrera, Fausto Baclig, and Alfredo Agulan as petitioners against the Third Division of the National Labor Relations Commission (NLRC), the National Service Corporation (NASECO), and Brig. Gen. Miguel Villamor (Ret.) as respondents. The events leading to this case began when the petitioners were dismissed from their positions at NASECO. On September 17, 1980, they filed a complaint for illegal dismissal with the Ministry of Labor and Employment. After reviewing the position papers from both parties, the Labor Arbiter ruled in favor of the petitioners on September 30, 1983, ordering their reinstatement without loss of seniority rights and awarding them two years of back wages and other benefits. This decision was subsequently affirmed by the First Division of the NLRC on December 9, 1985.
Following the affirmation, the petitioners sought a writ of execution to enforce the Labor Arbiter's decision. NASECO opposed this motion, claiming it had not...
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:
- Jurisdiction: Whether the NLRC had jurisdiction over the petitioners' complaint, given NASECO's status as a government-owned or controlled corporation.
- Applicability of the 1987 Constitution: Whether the 1987 Constitution, which governs government-owned or controlled corporations without original charters, applies to NASECO.
- 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.