G.R. No. L-47629 - Garcia vs. Martinez

Jose Velasco, Jr., the petitioner, filed a complaint in Civil Case No. 9657 for actual and moral damages amounting to P167,000 plus exemplary damages, arising from his dismissal as manager of a radio station.
The complaint did not include any prayer for reinstatement.

The Court of First Instance, Davao City Branch VI, initially entertained Velasco’s complaint.
On August 3, 1978, the lower court ruled that it lacked jurisdiction to hear the complaint because such cases were within the exclusive jurisdiction of Labor Arbiters under Article 217 of the Labor Code.
The Labor Code at that time provided that Labor Arbiters were empowered to decide cases arising from employer-employee relations, including claims for damages due to unjust dismissal.

Velasco based his second motion for reconsideration on Presidential Decree No. 1367, taking effect on May 1, 1978.
The amendment modified Section 217(a) of the Labor Code by explicitly stating that "the Regional Directors shall not indorse and Labor Arbiters shall not entertain claims for moral or other forms of damages."
The complete text of the amendment clarified the limitations of the Labor Arbiters’ jurisdiction regarding claims for damages.

It was determined that when Velasco’s complaint was originally filed, the lower court did not have jurisdiction; however, the subsequent issuance of Presidential Decree No. 1367 acted as a curative statute.
The curative statute had retrospective application to pending proceedings such as Civil Case No. 9657, effectively curing the jurisdictional defect.
The principle of retrospective application was reinforced with reference to established jurisprudence (See 82 C.J.S. 1004).

Whether the amendment enacted by Presidential Decree No. 1367, which restricted the jurisdiction of Labor Arbiters over moral and other forms of damages, can cure the jurisdictional defect that existed at the time the complaint was filed.
Whether the curative, retrospective effect of the amendment allows the lower court to properly exercise jurisdiction over Velasco’s pending case despite its initial lack thereof.