Title
Camporedondo vs. National Labor Relations Commission
Case
G.R. No. 129049
Decision Date
Aug 6, 1999
PNRC employee accused of cash shortage sought illegal dismissal claim; SC ruled PNRC as government corporation, placing jurisdiction under Civil Service Commission, not NLRC.
A

Case Digest (G.R. No. 129049)

Facts:

  • Background of employment
    • Petitioner Baltazar G. Camporedondo was employed by the Philippine National Red Cross (PNRC) since 1980 and served as Chapter Administrator of the Surigao del Norte Chapter until December 15, 1995.
    • PNRC paid staff are government employees, members of the Government Service Insurance System (GSIS) and covered by the Civil Service Law, owing a duty of uberrima fides (utmost good faith) in their service.
  • Audit and administrative actions
    • In July 1995, a PNRC field audit disclosed a cash shortage of P109,000.00 in the Surigao del Norte Chapter’s accounts.
    • On November 21, 1995, PNRC Secretary General Dr. Celso Samson demanded restitution within 72 hours of P135,927.78, representing cash and technical shortages plus unremitted collections.
    • On December 15, 1995, petitioner applied for early retirement under Presidential Decree No. 1146/Republic Act No. 1616 and requested an independent re-audit; the request was denied.
  • Labor complaint and procedural history
    • On May 28, 1996, petitioner filed with the NLRC (Sub-Regional Arbitration Branch X, Butuan City) a complaint for illegal dismissal, damages, and underpayment of wages against PNRC and its officials.
    • On June 14, 1996, PNRC moved to dismiss for lack of jurisdiction, contending that as a government-owned and controlled corporation (GOCC) under its original charter (RA No. 95), its employees fall under Civil Service jurisdiction.
    • Petitioner opposed on July 25, 1996, asserting a private-law employment relationship governed by the Labor Code.
    • The Labor Arbiter dismissed the complaint on October 11, 1996; motion for reconsideration was denied on November 12, 1996.
    • Petitioner appealed to the NLRC on November 20, 1996; on March 21, 1997, the NLRC Fifth Division affirmed the dismissal for lack of jurisdiction.
    • On July 7, 1997, the Supreme Court required respondent comment; PNRC filed on August 7, 1997, and the Solicitor General on November 7, 1997.

Issues:

  • Whether the PNRC is a government-owned and controlled corporation with an original charter such that its paid staff are covered by the Civil Service Law and the GSIS.
  • Whether the NLRC has jurisdiction over petitioner’s complaint for illegal dismissal and other labor claims against PNRC.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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