Case Digest (G.R. No. 240144)
Facts:
The case involves Del Monte Land Transport Bus Co., Inc. (DLTB) as the petitioner and a group of respondents consisting of various drivers and conductors, including Renante A. Armenta, Ronald C. Austria, and others. The events leading to the case began when the Department of Labor and Employment (DOLE) issued Department Order No. 118-12 on January 13, 2012, aimed at improving the working conditions and compensation of public utility bus drivers and conductors. On February 12, 2014, the DOLE's Regional Director issued Labor Standards Compliance Certificates (LSCC) to Del Monte Motor Works, Inc. (DMMWI), which owned DLTB, certifying compliance with the labor standards set forth in DO 118-12.
On July 28, 2014, the respondents filed a complaint against DLTB for underpayment of wages and non-payment of various benefits, including holiday pay, service incentive leave, and 13th month pay. They claimed that their daily salaries were below the minimum wage mandated by law. DLTB...
Case Digest (G.R. No. 240144)
Facts:
Background and DOLE Issuance
To ensure the protection and welfare of drivers and conductors in the public utility bus industry, the Department of Labor and Employment (DOLE) issued Department Order No. 118-12 (DO 118-12) on January 13, 2012. This order established a fixed and performance-based compensation scheme to improve working conditions, compensation, and competence of bus drivers and conductors, thereby enhancing public road transport safety.
Issuance of Labor Standards Compliance Certificates (LSCC)
On February 12, 2014, the DOLE, through its Regional Director, issued LSCCs to Del Monte Motor Works, Inc. (DMMWI), certifying compliance with DO 118-12 and other labor laws. These certificates were valid for one year unless revoked or canceled.
Complaint Filed by Respondents
On July 28, 2014, respondents, who are drivers and conductors hired by Del Monte Land Transport Bus, Co., Inc. (DLTB), filed a complaint for underpayment of wages and non-payment of benefits such as holiday pay, rest day premium, service incentive leave, 13th month pay, and other entitlements. They claimed their daily wages were P337.00, below the prevailing minimum wage of P466.00 in the National Capital Region (NCR), violating DO 118-12.
DLTB’s Defense
DLTB argued that prior to DO 118-12, respondents were paid on a purely commission basis. After its implementation, they were paid based on hours worked plus commission, which complied with the law. DLTB also cited the LSCCs issued to DMMWI as proof of compliance.
Jurisdictional Issue
DLTB raised the issue of jurisdiction, asserting that the Labor Arbiter (LA) had no authority to decide the case since the DOLE, through its Regional Office, had jurisdiction over labor standards compliance under DO 118-12 and Article 128 of the Labor Code.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
- Jurisdiction is conferred by law and determined by the nature of the claims and relief sought. Section 1, Rule VIII of DO 118-12 explicitly provides that the DOLE Regional Office has jurisdiction over compliance with minimum wages and wage-related benefits for public utility bus drivers and conductors.
- The issuance of LSCCs by the DOLE Regional Officer for DMMWI indicated that the DOLE had already assessed compliance with labor standards. The respondents' challenge to these certificates should have been lodged with the DOLE, not the Labor Arbiter.
- The amount claimed does not determine jurisdiction in labor standards cases. Article 128 of the Labor Code, as amended by RA 7730, grants the DOLE authority over such claims regardless of the amount, provided an employer-employee relationship exists.
- The CA erred in affirming the LA’s assumption of jurisdiction. The proper forum for addressing respondents' claims was the DOLE, as the case involved enforcement of labor standards under DO 118-12.
The Supreme Court emphasized that jurisdiction over labor standards claims is determined by law, not by the allegations or defenses of the parties. The DOLE has exclusive jurisdiction over such matters when an employer-employee relationship exists, regardless of the amount claimed. The CA’s decision was reversed, and the complaint was dismissed for lack of jurisdiction.
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