Case Digest (G.R. No. 240144)
Facts:
Del Monte Land Transport Bus, Co. v. Armenta, G.R. No. 240144, July 17, 2023, Supreme Court Third Division, Hernando, J., writing for the Court. The case arose from Department Order No. 118-12 (DO 118-12), issued by the Department of Labor and Employment (DOLE) on January 13, 2012, to regulate working conditions and prescribe a fixed-plus-performance compensation scheme for public utility bus drivers and conductors. On February 12, 2014, the DOLE Regional Director issued Labor Standards Compliance Certificates (LSCCs) certifying that Del Monte Motor Works, Inc. (DMMWI) had complied with DO 118-12; the certificates were valid for one year unless earlier revoked.On July 28, 2014, a group of drivers and conductors (the respondents) filed a complaint for underpayment of wages and other monetary benefits against Del Monte Land Transport Bus, Co., Inc. (DLTB). The respondents alleged they were paid daily rates below the applicable minimum and were deprived of 13th month pay, holiday pay, service incentive leave, rest day pay, overtime, and other benefits. DLTB contended respondents were paid under a fixed-hours-plus-commission scheme conforming to DO 118-12 and pointed to the LSCCs issued to DMMWI.
The Labor Arbiter (LA) (Eduardo J. Carpio), in a January 29, 2015 decision, found DLTB liable for respondents’ monetary claims and awarded P16,872,047.97, holding that DLTB’s principal office in Pasay City brought it within the ambit of the NCR wage order. The National Labor Relations Commission (NLRC), however, reversed on September 11, 2015, concluding the LA lacked jurisdiction because enforcement and compliance under DO 118-12 are to be made by the appropriate DOLE-Regional Office (DOLE-RO) pursuant to Article 128 of the Labor Code; the NLRC dismissed the complaint for lack of jurisdiction. The NLRC denied reconsideration on December 29, 2015.
On December 21, 2017 (amended June 7, 2018), the Court of Appeals (CA) reversed the NLRC and reinstated the LA’s decision, finding that the pri...(Subscriber-Only)
Issues:
- Did the Labor Arbiter have jurisdiction to hear respondents’ money claims, or did jurisdiction lie exclusively with the DOLE-Regional Office under Section 1, Rule VIII of DO 118-12 and Article 128 of the Labor Code?
- Did the Court of Appeals err on the merits in ruling that respondents were underpaid in ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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