G.R. No. 240144 - Del Monte Land Transport Bus, Co. vs. Armenta

To protect public utility bus drivers and conductors and promote safety, the Department of Labor and Employment (DOLE) issued DO 118-12 on January 13, 2012, prescribing a fixed and performance compensation scheme.
The objective was to improve working conditions, ensure proper compensation, and eliminate risk-taking behavior among drivers and conductors.

On February 12, 2014, DOLE's Regional Director issued Labor Standards Compliance Certificates (LSCC) to Del Monte Motor Works, Inc. (DMMWI), which owns and operates Del Monte Land Transport Bus, Co., Inc. (DLTB), certifying compliance with DO 118-12 and labor laws.
The certificates were valid for one year unless revoked or cancelled earlier.
DLTB is a corporation established on March 16, 2010, engaged in public utility transportation with principal office at 650 EDSA, Malibay, Pasay City, operating routes from Metro Manila to Batangas, Laguna, Bicol, and Visayas.
Respondents are bus drivers and conductors hired by DLTB between 2010 and 2013.

On July 28, 2014, respondents filed a complaint against DLTB alleging underpayment of wages, non-payment of holiday pay, holiday premium, rest day premium, service incentive leave, 13th month pay, and attorney’s fees.
They asserted their daily wages were P337.00, below the prevailing minimum wage of P466.00, violating DO 118-12, Section 2, Rule I paragraph (a).
DLTB argued that before DO 118-12, respondents were paid on a commission basis; after DO 118-12, payment was based on hours worked plus commissions (1% gross passenger revenue and 2.5% baggages revenue).
DLTB claimed the payments complied with the law and emphasized that the LSCCs were issued to DMMWI, not DLTB.
Respondents countered that DLTB’s Manila office is merely a transit point, not the principal office; therefore, minimum wage laws of the National Capital Region (NCR) should not apply.
DLTB raised the issue of jurisdiction, contesting the Labor Arbiter's (LA) authority, asserting that under Article 128 of the Labor Code, DOLE has exclusive jurisdiction over these claims.

The LA found DLTB’s principal office was in NCR, negating the “transit point” claim.
Held that NCR wage orders apply, thereby respondents were entitled to salary differentials and other benefits claimed.
Awarded monetary claims amounting to P16,872,047.97 for unpaid wages and benefits.

The NLRC ruled the LA acted with grave abuse of discretion in assuming jurisdiction.
Citing DO 118-12, NLRC held that enforcement of minimum wages and benefits is vested with the appropriate DOLE Regional Office having jurisdiction over the principal office of the employer.
Noted issuance of LSCCs to DMMWI five months prior to complaint as proof of compliance.
Directed dismissal of the complaint for lack of jurisdiction and recommended referral to DOLE-NCR.
Denied Motion for Reconsideration and Motion for Inhibition for lack of merit.

The CA reversed the NLRC ruling, reinstating the LA’s assumption of jurisdiction.
Held that money claims for underpayment of wages and benefits are within the jurisdiction of the Labor Arbiter and NLRC under Article 224 of the Labor Code.
Emphasized that jurisdiction is determined by allegations in the complaint and not defenses raised by respondents.
Amended decision only withdrew liability from Atty. Narciso O. Morales.

The CA erred in ruling the LA has jurisdiction when DO 118-12 expressly vests jurisdiction to DOLE Regional Offices.
The CA failed to properly apply DO 118-12 regarding underpayment of wages claims.

Whether the Labor Arbiter has jurisdiction over the complaint for underpayment of wages and other benefits of public utility bus drivers and conductors under DO 118-12.
Whether the DOLE Regional Office or the Labor Arbiter and the NLRC have jurisdiction to hear and decide the labor standards claims arising from alleged violations of DO 118-12.
Whether the CA correctly applied the law and previous Supreme Court rulings in overturning the NLRC decision dismissing the complaint for lack of jurisdiction.